ML20197F960
| ML20197F960 | |
| 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 | |
| 50-254-97-17, 50-265-97-17, EA-97-466, NUDOCS 9712300338 | |
| Download: ML20197F960 (45) | |
See also: IR 05000254/1997017
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December 18, 1997
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EA-466
Mr. L. W. Psarce
Site Vice President
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Ouad Cines Station
Commonwealth Edison Company
22710 206th Avenue North
Cordova,IL 61242
- UBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE SUMMARY
Dear Mr. Pearce:
On November 26,1997, you and members of Commonwealth Edison staff met with NRC
personnel in the Region 111 otCce located in Lisle, Illinois, to discuss the apparent violations
identified in NRC Inspection Report Nos. 50-254/97017(DRS); 50-265/97017(DRS). The
inspection report described several failures to properly implement key aspects of an adequate
maintenance rule program. The meeting was held at the request of Region Ill.
Commonwealth Edison agreed with the matenal facts detailed in the inspection report and did
not contest the apparent violations. During the conference, you indicated that the apparent
violations of 10 CFR 50.65 (the Maintenance Rule) were, primarily, the result of failure to
recognize the importance of the rule during the implementation phase, and inadequate
communication with regard to the nature and extent of the findings contained in the June 1997,
self-assessment, in response to these apparent violations, Commonwealth Edison embarked
on a comprehensive corrective action program to reexamine, revalidate, and revise, as
necessary, the Quad Cities Station maintenance rule program. In addition, processes were put
in place to ensure appropriate management oversight for self-assessment findings and provide
improved training for staff and management involved in the maintenance rule program. For the
corporate aspect of maintenance rule implementation, actions were taken to evaluate the status
of programs at Braidwood, Zion, and LaSalle Stations and to improve the interface between
corporate and the six stations. Commonwealth Edison's analysis of the problems with the
maintenance rule program and the corrective actions, both planned and in process, were
contained in a handout that was provided at the conference.
A copy of that handout, a summary of the apparent violations, and an attendance list from the
conference are enclosed with this summary.
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ADOCK 05000254
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L. W. Pearce
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Deconber 18, 1997
1,1 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 (PDR).
Sincerely,
/s/ J. A. Grobe
John A. Grobe, Director
Division of Reactor Safety
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Docket Nos. 50-254; 50-265
Enclosures:
As stated
cc w/encls:
O. Kingsley, Nuclear Generation Group
President & Chief Nuclear Officer
M. Wallace, Senior Vice President,
Corporate Services
E. Kraft Vice President, BWR Operations
Liaison Office NOC-BOD
D. A. Sager, ace Fresident,
Generation Support
D. Farrar, Nuclear Regulatory
Services Manager
I. 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 Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission
W. D Leech, Manager of Nuclear,
MidAmerican Energy Company
Distribution
Docket File w/encls
F.Ill PRR w/encls-
Rill Enf. Coordinator w/encls
PUBLIC IE-01 w/encls
SRI, Quad Cities w/encls
TSS w/encls
LPM, NRR w/ enc;s
J. L. Caldwell, Rill w/encls
R. A. Capra, NRR w/encls
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DRP w/encls
A. B. Beach, Ril! w/encls
DOCDESK w/encls
DRS w/encls
i AA1 w/encls
DOCUMENT NAME: G:DRS\\QUA12167.DRS
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DATE
12/l5'/97
12/gf97 (
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OFFICIAL RECORD COPY
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ENFORCEMENT CONFERENCE
ATTENDANC.E LtST
- Date: November 26,1997 .
Licensee:
Commonwealth Edison
Quad Cities Station -
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NRC Attendees
' A. Beach, Regional Administrator
J.. Grobe, Director, DRS
H. Clayton, EICS
J. Gavula, Branch Chief, ESB1
M. Ring, Branen Chief. Br 1
M. Fartier, Reactor lospector
L. Collins, RI, QC
Comed Attendees
G. Stanley, Vice President - PWR
B. Pearce, Site Vice President
' R. Flessner, Manager of Q&SA
J. Meister, Engineering Mgr, Braidwood
R. Helfrich, Sr. Counsel- Nuclear
C. Peterson, Regulatory Staffing Manager
D. Sager, VP - Generation Support
D. Wozniak, Engineering Mgr - Byron
J. Luke, Engineering Mgr - Zion
C. Sibley, Comed Maintenance Rule Owner
P. Wojtkiewicz, Dresden Maintenance Rt:le Owner
M. Sharma. LaSalle Maintenance Rule Owner
G. Poletto, LaSalle Site Engineering Managor
M. Heffley, Dresden Station Manager
J. Williams, Project Manager - Nuclear Operations
T. Roberts, Peer Support Engr. Mgr.
R. Fmeman, Site Engineenng Manager - Dresden
J. Purkis, System Engineer Supervisor
A. Javorik, Comp. Maintenance Manager
D. Craddick, Maintenance Rule Owner
F. Familari, Q&SA Manager
MidAmerican
D. Tubbs, Ser. lor Engineer - Nuclear
IDMS
B. Ganser
Public
E. Linthicum
N, Linthicum -
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Maintenance Rule
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Agenda
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Opening Comments
Bill Pearce
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Program issues and Actions
Jack Purkis
Corporate Initiatives
Alex Javorik
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Closing Remarks
Gene Stanley
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Opening Comments
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Comed Concurs With NRC Findings
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Significant Program Deficiencies
Positive Aspects
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1997 Self Assessment identified Many
Issues, but Response Not Adequate / Timely
Improvement Plan Being Aggressively
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Pursued
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Comed Quad Cities Station
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Issues and Actions
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System Engineering Supervisor
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Issues and Actions
Implementation Effort
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June 1997 Self Assessment
September 1997 NRC Inspection Findings
Causes and Significance
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Corrective Actions / Improvement Plan
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Implementation Effort
Resources Applied (1995-1993)
Implementation Team
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Expert Panel Established
Milestones Tracked to Completion in
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Management Plan
Pre-Implementation Q&SA Assessments
Performed (1995 and 1996) and Actions
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8 Systems Placed in (aX1) (1996)
Training / Instruction Provided
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Post-July 1996
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(aX1) Systems Added
Periodic Evaluation Performed as Required
by The Rule (October 1996)
-On-Line Risk Adequately Monitored
-Site Structural Baseline Inspection to Be
incorporated into Program
Training / Instruction Provided
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June 1997 Self Assessment
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Performed Comprehensive Self Assessment
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Based on NUMARC 93-01, NRC IP 62706, and
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PRA and Structural Specialist
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June 1997 Self Assessment
Concerns identified by Team
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Performance Criteria
(aX1) Goal Setting
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Program Documentation
Additional MPFF Guidance
Recommended
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June 1997 Self Assessment
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Actions (July - September 1997)
Strengthened Program
Reconvened Expert Panel
Initiated Rescoping - Addec Systems to
Scope
Dispositioned Systems to (a)(1)
Initiated Corrections to Performance Criteria
and to (a)(1) Goals
Response Not Adequate / Timely
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September 1997
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NRC Inspection Findings
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Four Apparent Violations
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Scoping Omissions
Inac equate Performance Criteria
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Inadequate Goal Setting
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Causes
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Station Management Did Not Demonstrate the
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Maintenance Rule was Viewed as important
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Inadequate Response to 1997 Self
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Management Not Fully Cognizant of Depth of
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Management not adequately informed regarding
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Recognize Significance of Programmatic Compliance Issues
Near-Term Safety Significance Low
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Monitoring Programs in Place
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On-Line Risk Assessment Good - Use of Operational
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Safety Predictor Software and IPEEE Fire Risk Study
Noted as Strength
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Material Condition improvements Noted
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Importance of Program Recognized for Monitoring Long Term
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Maintenance Effectiveness
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Management and Independent
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Improvement Plan
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Management and Independent Oversight
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Current Program Oversight
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Station Top 10 Issues List
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Effectiveness of the Corrective Actions to the
Program
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Senior Manager Assignec
Status of Corrective Actions Reported Weekly
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Developing Procedure Guidance for
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Tracking of Self Assessment issues in
Corrective Action Program
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Elements of Plan
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Industry Expert
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Maintenance Rule Engineer
3 Contractors Experienced With Maintenance
Rule implementation
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Expert Panel Reconvened for Program
Oversight
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Improvement Plan
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Actions and Schedule
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Commitment
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Re-Perform Scoping
10/15/97 Complete
(Began July 1997)
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Reset Performance Criteria
10/15/97 Complete
(Began July 1997)
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Complete Historical Data Review
01/28/98 - On Schedule
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of High Risk Significant SSCs
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Establish Revised Goals and
02/14/98 - On Schedule
Action Plans for High Risk
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Complete Historical Data Review
02/28/98 - On Schedule
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of Low Risk Significant Systems
Establish Revised Goals and
03/15/98 - On Schedule
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Action Plans.for Low Risk
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Significant Systems Determined
to Be (a)(1)
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Conduct an in-Depth Assessment
04/98
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of the Maintenance Rule Program
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Other initiatives
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Schedule
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Training and Instruction
Expert Panel Decision Criteria
08/97
System Engineer Functional Failure
12/97
Evaluations
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12/97
Developing Enhanced Maintenance
1st Qtr 98
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Rule Training (Corporate Action)
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Incorporating Maintenance Rule
1st Qtr 98
Tasks into System Engineenng
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Qualification Card
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Benchmarking
1st Qtr 98
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Improvement Plan Being Aggressively
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Maintenance Effectiveness
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Corporate Maintenance Rule
Initiatives Based on Quad Cities
Lessons Learned
Alex Javorik
Component Maintenance Manager
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Immediate Actions Following Quad
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Commun.ication Improvements
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Quad Cities Inspection
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Conducted Q&SA Assessments at
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Q&SA and Outside Expertise
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Looked Specifically for Weaknesses Found at
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Quad Cities and Elsewhere in Industry
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Assessments Were/Are Being shared With
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Assessment Results at Braidwood, LaSalle
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improvemen~: Plans Developed and Teams
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Improvements Are in Progress at All Stations
Site Management Understands the Signncance
of the issues
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Counterparts identified at Corporate
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Regular Reports to Site Engineenng
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Regularly Scheduled Forums :o Assess
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improvement Progress
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Re-examine Risk Significance
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Criteria
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Focus on improving Level of Documentation
Pertaining to Decision Making
Reassessing System Performance
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Closing Remarks
H. Gene Stanley
Vice President - PWR
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Comed Quad Cities Station
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Enforcement Conference
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Scoping of SSCs inapproariately Excluded
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Some Functions (01)
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HPCI AutomaticTrips
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Reactor Manual Controi
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Intraplant Communications
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Corrective Actions
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Contracted Industry Expert
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Scoping Standards
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Completed 08/97
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Rescoped Systems
Completed 10/97
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Scheduled 04/98
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Unacceptable Performance Criteria
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Reliability Criteria Not Supported by the PRA (04a)
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Inappropriate Performance Criteria
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Inappropriate Availability Criteria (04b,04c)
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Insufficient Performance Criteria for High Safety
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Significant Functions (04d)
Performance Criteria With No Predictive Value
(04e)
Inappropriate Use of Plant Level Performance
Criteria (04f)
Performance Criteria Can Not Be Monitored (04g)
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Unacceptable Performance Criteria
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Corrective Actions
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Performance Criteria Standards
Completed 08/97
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Reviewed With the Expert Panel
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Industry Expert Chairing Expert Panel *
Started 08/97
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PRA Sensitivity Run
Completed 09/97
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Reviewed and Revised
Completed 10/97
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Performance Criteria
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Program independent Assessment
Scheduled 04/98
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Inadequate Evaluation and Monitoring
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Against Performance Criteria
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Inadequate Evaluation and Monitoring
Against Performance Criteria
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Corrective Actions
Status
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Training of System Engineers
Started 10/97, Scheduled 12/97
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On Schedule
Issued Enhanced Guidance
Complete 11/7/97
-
,
on Functional Failure Evaluations
'
Perform Evaluations
Started 10/97, cicheduled 01/28/98
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of High Safety Significant Systems
On Schedule
Perform Evaluations
Started 10/97, Scheduled 2/28/98
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of Low Safety Significant Systems
On Schedule
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-
Review / Oversight cf Functional Failure
Started 10/97, On Schedule
!
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Evaluations by MR Team
!
Revise Procedure to Address
Scheduled G3/98, On Schedule
!
-
Oversight of Functional Failures
!
Program independent Assessment
Scheduled 04/98
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B7
!
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.
y _-
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Inadequate and Untimely Goals
x _ m_________________
Goals Not Established in a Timely
-
-
Manner (06a}
Inadequate Technical Justification For
-
Established Goals
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(06b)
No Goals or Monitoring on Some
-
Systems (06c)
88
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L_
. _
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.
. _ _
.
.
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_ _
. _
. _ _ _ .
,
__
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Inac equate and Untimely Goals
Corrective Actions
Status
Proceduralized Expert Panel Oversight of
-
(a)(1) System Action Plans and Goals
Completed 8/97
Issue Guidance on Goal Setting
Completed 11/97
-
Training of System Engineers on
Started 10/97
-
Goal Setting
Scheduled 12/97,
On Schedule
Goal Resetting of High Safety Significant
Started 10/97
-
Scheduled 2/14/98,
Systems
On Schedule
Goal Resetting of Low Safety Significant
Started 10/97
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l
Scheduled 3/15/98,
Systems
On Schedule
Program Independent Assessment
Scheduled 04/98
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o
The cpp rent viol:tions discussed ct the predecision:1 ent:rciment confirezc2 cre sIbject to
further rev'cw aid s:bject ta change prior to sny resulting enforcemert cction.
i
'
APPARENT VIOLATIONS
A.
10 CFR S0.65(A)(1) REQUIRES, IN f* ART, THE HOLDERS OF AN OPERATING
LICENSE SHALL MONITOR THE P?RFORMANCE OR CONDITION OF
STRUCTURES, SYSTEMS OR COMPONENTS (SSCS), AGAINST LICENSEE.
ESTABl.lSHED GOALS.
CONTRARY TO THE ABOVE:
1.
BETWEEN APRIL 10,1997, THROUGH AUGUST 7,1997, THE LICENSEE
FAILED TO MONITOR THE PERFORMANCE AND ESTABLISH GOALS
COMMENSURATE WITH SAFETY FOR THE CONTAINMENT ATMOSPHERIC
MONITORING SYSTEM ALTHOUGH THE SYSTEM WAS CLASSIFIED AS
(A)(1) ON APRIL 10,1997.
2.
AS OF SEPTEMBER 12,1997, THE LICENSEE HAD FAILED TO MONITOR
THE PEHFORMANCE AND ESTABLISH GOALS COMMENSURATE WITH
SAFETY FOR THE STATION BLACKOUT DIESEL GENERATORS.
3.
BETWEEN JULY 10,1996 AND AU3UST 1997, THE LICENSEE FAILED TO
MONITOR THE PERFORMANCE AND ESTABLsSH GOALS
COMMENSURATE WITH SAFETY FOR THE RESIDUAL HEAT
REMOVAURESIDUAL HEAT REMOVAL SERVICE WATER SYSTEMS.
B.
10 CFR 60.65(A)(1) REQUIRES, IN PART, THE HCLDERS OF AN OPERATING
LICENSE SHAI.L MONITOR THE PERFORMANCE OR CONDITION OF SSCS,
"
AGAINST LICENSEE-ESTABLISHED GOALS.
10 CFR 50.6S(A)(2) REQUIRES, IN PART, THAT MONITORING AS SPECIFIED IN
10 CFR S0.65 (A)(1) IS NOT REQUIRED WHERE IT HAS BEEN DEMONSTRATED
THAT THE PERFORMANCE OR CONDITION OF AN SSC IS BEING EFFECTIVELY
CONTROLLED THROUGH THE PERFORMANCE OF APPROPRIATE PREVENTIVE
MAINTENANCE, SUCH THAT THE SSC REMAINS CAPABLE OF PERFORMING ITS
INTENDED FUNCTION.
CONTRARY TO 10 CFR 50.65(A)(2), AS OF JULY 10,1996, THE TIME THAT THE
LICENSEE ELECTED TO NOT MONITOR THE PERFORMANCE OR CONDITION OF
CERTAIN SSCS AGAINST LICENSEE ESTABLISHED GOALS PURSUANT TO THE
REQUIREMENTS OF SECTION (A)(1), THE LICENSEE FAILED TO DEMONSTRATE
THAT THE PERFORMANCE OR CONDITION OF SSCS WITHIN THE SCOPE OF 10 CFR 50.65 HAD BEEN EFFECTIVELY CONTROLLED THROUGH THE
PERFORMANCE OF APPROPRIATE PREVENTIVE MAINTENANCE, AS
EVIDENCED BY THE FOLLOWING EXAMPLES:
i
The apparent violations discussed at the predecisional enforcement conference are subject to
further review and subject to change prior to any resulting enforcement action.
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y j t?
The cpp: rect viol:tio:s discused ct the predecislo::1 e:forcement ec2fere:ce are subject to
' further review and subject to change prior to any resulting enforcement action.;
i
1.
ESTABUSHED MEASURES FOR THE HIGH SAFETYSIGNIFICANCE
PRESSURE BOUNDARY FUNCTION OF THE NUCLEAR BOILER
INSTRUMENTATION, SOURCE RANGE MONITOR DRIVE CONTROL,
- RECIRCULATION, STANDBY UQLND CONTROL, REACTOR CORE
'
ISOLATION COOUNG, AND HIGH PRESSURE COOLANTINJECTIO*] HAD
AN UNACCEPTABLE STAND-ALONE REUABlUTY MEASURE OF NO
,
REPETITIVE MAINTENANCE PREVENTABLE FUNCTIONAL FAILURES, NO
UNAVAILABlUTYMEASURE, AND A CONDITION MONITORING MEASURE
,
,
"
OF NO THROUGH WALL LEAKAGE THATHAD NO PREDICTIVE VALUE.'
2.
THERE WAS NO TECHNICAL JUSTIFICATION SUPPORTING REUABlUTY
MEASURES THAT WERE INCONSISTENT WITH THE ASSUMPTIONS IN THE
i
LICENSEE *S PROBABlUSTIC RISK ASSESSMENT FOR THE HIGH SAFETY
SIGNIFICANCE FUNCTIONS OF THE 4160 VOLT SWITCHGEAR CROSSTIE,
480 VOLT TRANSFORMER,480 VOLTSWITCHGEAR, AND THE 250 VOLT
.
DC SYSTEM.
-
3.
BETWEENJULY10,1996 AND AUGUST 20,1997, ONLYUNPLANNED
UMITING CONDITION FOR OPERATION TIME WAS SPECIFIED AS AN
l
UNAVAILABlUTY PERFORMANCE MEASURE FOR HIGH SAFETY -
SIGNIFICANCE FUNCTIONS OF THE INTERNAL FLOOD PROTECTION,
[
AUTOMATIC DEPRE*SURIZATION, AND STANDBY GAS TREATMENT
SYSTEMS.
- .
4.
THE UCENSEE HAD ESTABLISHED A RELIABILITYMEASURE, BUT
ESTABLISHED NO AVAILABIUTYMEASURE FOR THE HIGH SAFETY
.
.
SIGNIFICANCE FUNCTIONS OF THE 480 VOLT TRANSFORMERS AND .
l?
SWITCHGEAR, REACTOR BUILDING HEATING, VENTILATION, AND AIR
CONDITIONING, FIRE PROTECTION ALTERNATE WATER SUPPLY TO A
- REACTOR PRESSURE VESSEL,4160 VOLTSWITCHGEAR, AND 345KV
- SWITCHYARD.
5.
THE UCENSEE ESTABUSHED PLANT LEVEL PERFORMANCE MEASURES
WHICH COULD NOT DEMONSTRATE PROPER PERFORMANCE OF
FUNCTIONS OF THE ROD POSITIONING, PROCESS COMPUTER, AND 120
l.
VOLT AC COMPUTER UNINTERRUPTIBLE POWER SUPPLY SYSTEMS.
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6.
THE UCENSEE ESTABUSHED MEASURES FOR FUNCTIONS OF THE -
NITROGEN SYSTEM WHICH HAD NO SURVEILLANCE ACTIVITY THAT .
WOULD PROVIDE THE INFORMA TION NECESSARY TO DEMONSTRATE
i
ADEQUATE PREVENTIVE MAINTENANCE.
,
j;
7.
THE UCENSEE ESTABUSHED AN AVAILABILITYMCACURE WHICH DID
NOT PROVIDE AN ADEQUATE BASIS TO DEMONSTRATE EFFECTIVE '
.~ PREVENTIVE MAINTENANCE FOR FUNCTIONS OF THE CONTAINMENT
. ATMOSPHERIC MONITORING,125 VOLTDC, AND 250 VOLTDC SYSTEMS.
.
The apparent violations discussed at the predecisional enforcement conference are subject to
,
_
further review and subjet to change prior to any resulting enforcement action.
!
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-- Thieppare:t viol tions discussed at the predecisioul e:f:rcemest conferesco cre sIbject ts
[
frrther review and subject to change prior to any resulting enforcement action.
C.
'10 CFR 50.65(A)(1) REQUIRES, IN PART, THE HOLDERS OF AN OPERATING
LICENSE SHALL MONITOR THE PERFORMANCE OR CONDITION OF
STRUCTURES, SYSTEMS OR COMPONENTS (SSCS), AGAINST LICENSEE.
ESTABLISHED GOALS.
,
10 CFR 50.65(A)(2) REQUIRES, IN PART, THATMONITORING AS SPECIFIED IN
'
10 CFR 50.65 (A)(1) IS NOT REQUIRED WHERE IT HAS BEEN DEMONSTRATED
i
THAT THE PERFORMANCE OR CONDITION OF AN SSC IS BEING EFFECTIVELY
CONTROLLED THROUGH THE PERFORMANCE OF APPROPRIATE PREVENTIVE
MAINTENANCE, SUCH THAT THE SSC REMAINS CAPABLE OF PERFORMING ITS '
INTENDED FUNCTION.
.
CONTRARY TO 10 CFR 50.65(A)(2):
i
1.
BETWEEN JULY 10,1996 AND APRIL 10,1997, THE LICENSEE FAILED TO
PROPERLY CONSIDER MAINTENANCE PREVENTABLE FUNCTIONAL
FAILURES WMCH OCCURRED DURING 1995 AND 1996 FOR THE
l
EMERGENCYDfESEL GENERATORS AND INCORRECTLY CLASSIFIED
'
THE EMERGENCYDIESELS AS CATEGORY (A)(2)
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2.
BETWEENJULY10,1996 AND AUGUST 22,1997, THE LICENSEE FAILED
TO CONSIDER MAINTENANCE PREVENTABLE FUNCTIONAL FAILURES
l
PRIOR TO JULY 10,1996 FOR THE CONTROL ROD DRIVE HYDRAULIC
'
CONTROL UNIT ACCUMULATOR NO.115 CHECK VALVES, SHUTDOWN
COOLING PERMISSIVE PRESSURES SWITCHES, AND THE 480 VOLT AC
BREAKER FOR MOTOR OPERATED VALVE 1 100126B AND
'
!:
INCORRECTLY ALLOWED THESE FUNCTIONS TO REMAIN UNDER
SECTION (A)(2).
3.
BETWEEN NOVEMBER 22,1996 AND APRIL 10,1997, THE LICENSEE
FAILED TO PROPERLY CONSIDER SURVEILLANCE FAILURES OF THE
l
CONTAINMENT ATMOSPHERIC MONITORING SYSTEM WHICH
l'
OCCURRED BETWEEN FEBRUARY 25,1996 AND NOVEMBER 22,1996
l.
AND INCORRECTLY CLASSIFIED THE CONTAINMENT A TMOSPHERIC
ll
MONITORING SYSTEM AS CATEGORY (A)(2).
l
4.
BETWEEN APRIL 19,1997 AND AUGUST 22,1997, THE LICENSEE FAILED
,
l
TO PROPERLY CONSIDER A MAINTENANCE PREVENTABLE FUNCTIONAL
,
FAILURE OF THE SCRAM FUNCTION OF A SCRAM DISCHARGE VOLUME
,
LEVEL TRANSnNTTER WHICH OCCURRED ON APRIL 19,1997, AND
'
INCORRECTLY ALLOWED IT TO REMAIN UNDER SECTION (A)(2).'
5.
-- BETWEEN JULY 10,1996 AND SEPTEMBER 12,1997, THE LICENSEE '
FAILED TO PROPERLY CONSIDER THE REPAIR AND REPLACEMENT OF .
~ ELECTRONIC CARDS REQUIPED FOR THE PERFORMANCE OF
FUNCTIONS OF THE SOURCE RANGE, INTERMEDIATE RANGE,' LOCAL
. POWER RANGE, AND AVERAGE POWER RANGE NEUTRON MONITORING
SYSTEMS AND INCORRECTLY ALLOWED THEM TO REMAIN UNDER
SECTION(A)(2).
' The apparent violations discussed at _the predecisional enforcement conference are subject to
further review and subject to change prior to any resulting enforcement action.
_
.
.. . .
.
.
.
- - .
-.
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- - -
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.
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- ./ p, i
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a !'
The cpparent violations discussed ct the predecisionil enforcement enference cre nbject ta
further review and subject to change prior to any resulting enforcement action.
D.
10 CFR 50.65(B) REQUIRES, IN PART, THAT *THE SCOPE OF THE MONITORING
PROGRAM SPECIFIED IN PAR AGRAPH (A)(1) OF THIS SECTION SHALL INCLUDE
SAFETY RELATED AND NONSAFETYRELATED STRUCTURES, SYSTEMS, AND
COMPONENTS, AS FOLLOWS":
(2)
... STRUCTURES, SYSTEMS OR COMPONENTS: (I) THAT ARE RELIED
UPON TO MITIGATE ACCIDENTS OR TRANSIENTS OR ARE USED IN
PLANT EMERGENCY OPERA TING PROCEDURES; OR (II) WHOSE FAILURE
COULD PREVENT SAFETY-RELATED STRUCTURES, SYSTEMS, AND
COMPONENTS FROM FULFILLING VMEIR SAFE 1Y-RELATED FUNCTION;
OR (III) WHOSE FAILURE COULD CAUSE A REACTOR SCRAM OR
ACTUATION OF A SAFETY RELATED SYSTEM.
CONTRARY TO THE ABOVE,
1.
AS OF SEPTEMBER 12,1997, THE LICENSEE HAD FAILED TOIDENTIFY
AND INCLUDE THE AUTOMATIC TRIP FUNCTIONS OF THE SAFETY-
RELATED HIGH PRESSURE COOLANTINJECTION PUMP TURBINE IN THE
SCOPE OF THE MAINTENANCE RULE.
2.
AS OF AUGUST 21,1997, THE LICENSEE FAILED TO INCLUDE THE ROD
.
BLOCK FUNCTION OF THE REACTOR MANUAL CONTROL SYSTEM IN
THE SCOPE OF THE MAINTENANCE RULE.
3.
PRIOR TO AUGUST 15,1997, THE LICENSEE HAD FAILED TO INCLUDE
THEINTRAPLANT COMMUNICATIONS SYSTEMS, RELIED UPON TO
MITIGATE THE CONSEQUENCES OF ACCIDENTS OR TRANSIENTS, IN THE
SCOPE OF THE MAINTENANCE RULE.
-
.
1
The apparent violations discussed at the predecisional enforcement conference are subject to
further review and subject to change prior to any resulting enforcement action.