ML20199E050

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Summarizes 980109 Predecisional Enforcement Conference Held in Lisle,Il Re Apparent Violations & Unresolved Item Identified in NRC Insp Repts 50-254/97-27 & 50-265/97-27. Handouts,Summary of Violations & List of Attendees Encl
ML20199E050
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 01/23/1998
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
50-254-97-27, 50-265-97-27, EA-97-591, NUDOCS 9802020082
Download: ML20199E050 (53)


See also: IR 05000254/1997027

Text

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January 23, 1998

EA 97-5911

Mr. Oliver D. Kingsley

President, Nuclear Generation Group

Commonwealth Edison Company

ATTN: Regulatory Services

Executive Towers West 111

1400 Opus Place, Suite 500

Downers Grove,IL 60510

SUBJECT: NRC PREDECISIONAL ENFORCEMENT CONFERENCE SUMMARY

Dear Mr. Kingsley;

On January 9,1998, members of Commonwealth Edison staff met with NRC personnelin the

Region Ill office located in Lisle, Illinois, to discuss the apparent violatiors and unresolved item

Ider,tified in the NRC Inspection Report Nos. 50-254/97027(DRS); 50-265/97027(DRS), The

inspection report described several failures in your program to properly implement key aspects

pertaining to the American Society of Mechanical Engineers Code,Section XI, Class 1 and 2

pressure testing. The conference was held at the request of Region Ill.

Commonwealth Edison agreed with the facts detailed in the inspection report and did not i

contest the apparent violations. During the conference, Commonwealth Edison discussed a

number of causes for these violations which included: lack of senior management review, lack

of awareness of the applicable requirements, personneljudgement and performance errors, ,

and ineffective self assessment. Additionally, Commonwealth Edison addressed the

unresolved item and acknowledged that the VT-2 exaraination of the Class 1 system completed

on June 22,1997, was inadequate with respect to Code requirements. Commonwealth Edison

based this conclusion on a January 3,1998, re-enactment of the VT-2 examination, which

- demonstrated that leakage (if present) would not hcva been detected in several areas of the

. Class 1 system boundary. In response to these apparent violations and unresolved item,

Commonwealth Edison had initiated generally comprehensive corrective actions. NRC staff

review of these corrective actions is in process and will be addressed in subsequent

correspondence. Commonwealth Edison's analysis of these problems and the corrective

>

actions, both planned and in process, was 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.

9902020082 990123 -

PDR ADOCK 05000254

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O. D. Kingsley 2 January 23. 1998

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of :: tis letter and its

enclosures wih he placed in the NRC Public Document Room (PDR).

Sincerely,

original signed by J. A. Grobe

John A. Grobe, Director

Division of Reactor Safety

Docket Nos. 50-254; 50-265

License Nos. DPR 29; DPR-30

Enclosures: As stated

cc w/encls: M. Wallace, Senior Vice President,

Corporate Services

J. Perry, Vice President, BWR Operations

E. S. Kraft, Jr., Site Vice President ~

Liaison Officer, NOC-BOD

D. A. Sager, Vice Presloent,

Generation Support

D. Farrar, Nuclear Rogulatory

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 Commerce Commission

W. D. Leech, Manager of Nuclear,-

MidAmerican Energy Company

Distribution

Docket File w/encls Rlli PRR w/encls Rlil Enf. Coordinator w/encls

PUBLIC IE-01 w/encls SRI, Quad Cities w/encls TSS w/encls

LPM, NRR w/encls J. L. Caldwell, Rlli w/encls R. A. Capre, NRR w/encls

DRP w/encls A. B. Beach, Rill w/encls DOCDESK w/encls

DRS w/encls CAA1 w/encls J. Lieberman, OE

J. Goldberg, OGC R. Zimmerman, NRR

DOCUMENT NAME: G:DRS\qua01148.drs

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OFFICE Rill (i Rill ,. C- Rlli l C- l Rlli , .,

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NAME MHolmberg:sd & JGavulaW MRing W JGrob(,[/W

DATE 01/H/98 01/ll/98 l{ V 01h5/98 01/759/

OFMCIAL RECORD COPY

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Appendix G .

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Pre-Decisional Enforcement

Conference

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January 9,1998 ,

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A Unicom Company

Agenda

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Introduction Edward S. Kraft, Jr.

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Onening Remarks Bill Pearce

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Background Chris Hebel l

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Operational Safety Focus Bob Svaleson  !

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Findings Issues and Actions Jack Purkis

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Comed VT-2 Program John Hutchinson

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Closing Remarks Edward S. Kraft, Jr.

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Introduction ,

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Edward S. Kraft. a. .

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Quad Cities Station

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Site Vice President

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Opening Remarks

Bill Pearce

Quad Cities Station

General Station Manager

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Opening Remarks

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Comed and Quad Cities Station Enderstand the  !

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Seriousness of the Issues

Recognize Increased Risk of L sing Nuclear Heat

and Saturated Conditions Before Completion of

Pressure and Leak Tests on the Reactor Pressure

Vessel

Complex Story Involving Several Poor Decisions

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We Accept the Violations

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A Unicom Company

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Background

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Chris Hebel

Quad Cities Station

Test Director

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A Unicom Company

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Background

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Explanation of Pressure Test

Pressure Control Methods

>> Temperature Control Methods

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Background

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June 1996 - Began Development ofNew

Pressure / Temperature Curves (P/T)

Needed Prior to 16 EFPY

Utilized New Methodology

>> Addressed Lower Head P/T Limits

P/T Limits Shifted 20 Higher

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Background

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July 10,1996 - Meeting to Discuss New P/T

Curves

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Concern Regarding Controlin Narrow t

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Temperature Band

Discussed Options

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September 20,1996 - Submitted New P/T

Curves to NRC

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P/T Curve

, 1020 _ #

$ 212 F Mode 3 Limit

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1010 Operating Margin For

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E OPERATING BAND

$ I""" -

WITH THE NEW '

E PRESSURE

( AT Bulk Water

TEMPERATURE

CURVE

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o Temp. to Lowest

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Metal Temp.

980

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180 190 200 210 220

Temperature ( a F )

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Background

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September 26,1996 - Implemented Upgraded

Technical Specifications

Defined Mode Change at 212 F

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October 1996 - Meeting to Consider Performing

Pressure Tests While Critical

Decided Not to Test Critical

Winter 1996 - Developed Plan to Establish

Primary Containment Prior to Pressure Test

Allow Reactor Water Temperature to Exceed 212 F

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Background

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March 25,1997 - New Pressure / Temperature

Curves Inserted Into Technical Specifications

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May 1997 - Pre-Test Review Recognized Mode 3

Requirements at 212 F

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Could Not Meet Mode 3 Requirements During

Test

Reconsidered Options

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Background

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Options Considered

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Control Temperature in Tight Band

Request Regulatory Relief

Test While Critical

Option Selected

Perform 850 psi Pre-Test and Perform Code

Pressure Vessel Test After Criticality

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Background

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Applied Routine Processes

Changed Procedures

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Performed Simulator Run

50.59 Screenmg

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Startua Checklist

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Background

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May 24,1997 - Performed Preliminary Pressure

Leakage Test at 850 psi

- June 8,1997 - E nit 2 Critical

- June 12,1997 - Enit 2 Critical

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June 22,1997 - Performed Code Required Vessel

Pressure Leakage Test  !

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October 1,1997 - Recognized 10CFR50

Appendix G Requirement for Testing Before

Reactor Critical

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Operational Safety Focus

Bob Svaleson

Quad Cities Station

Operations Manager

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Operational Safety Focus

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Examples of Proper Actions

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What Should Have Happened?

. Should Have Known of Appendix G Change

>> Should Have Had PORC Review

On-Site Review Should Have Raised the Issue

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Findings -

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Issues and Actions

Jack Purkis

Quad Cities Station

System Engineering Supelvisor

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Violation of Appendix G

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NRC Inspection Finding

Failure to Perform Lnit 2 ASME Code

Section XI Class 1 Leakage Test Prior to

Criticality (EEI 01)

We Agree With This Finding

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Violation of Appendix G

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Causes

! >> No Senior Manager Collegial Review

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Lack of Awareness ofNew Appendix G Revision

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-Ineffective Tracking ofNew or Changed Rules and

Regulations

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-Insufficient Research to Identify Appendix G Change

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Violation of Appendix G

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Corrective Actions

SVP Will Discuss This Finding at Next Station "All

Hands" Meeting

An Assessment Has Been Completed to Determine

Which Procedures Should Receive an Additional

PORC Review Prior to Implementation.

Station Has Put in Place, in Interim, a Process to

Ensure Notifications of All Rule Changes

All Applicable Rule Changes Will Be Distributed and

Tracked by OPEX

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Violation of Appendix G

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Corrective Actions (Cont.)

The Rule Changes for the Last 3 Years Have Been

Reviewed for Applicability

>> Xew Corporate Wide System for Tracking and

Distributing New or Changed Rules and Regulations Is

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Being Developed

Station Startup Procedure Has Been Revised to Include

the Appendix G Requirement

l This Finding Will Be Incorporated Into License

Operator Requalification Lessons Learned Which Will

Be Completed February 20,1998 22

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Violation of Appendix G

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Corrective Actions (Cont.)

Station Procedures and Processes Are Being Reviewed

to Verify All Requirements of Appendix G Are Being

Met. This Will Be Completed by February 28,1998

The 10CFR50 in the Technical Library Will Be

Handled As a Controlled Copy. This Will Be

Completed by January 31,1998

Training Will Be Completed for Persons Who Conduct

Cross Discipline Review to Ensure Applicable Codes

and Standards Are Reviewed.

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Violation of Appendix G

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Safety Significance

Safety Significance Was Mitigated .

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- Pre-Te.st at Approximately 840 psig Conducted in the Same i

Manner As Code Test

- Probability of Test Propagating a Crack Through Wall Is

Approximately the Same for a 850 or 1005 psig Test

- 55% Of Reactor Vessel Shell Welds Had Volumetric Exams

During Outage

- Unidentified Leakage at Startup Was Approximately 0.5

Gallons Per Minute

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Inadequate 50.59 Safety Evaluation

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NRC Inspection Finding

Failure to Perform Adequate 50.59 Safety

Evaluation for the Test Procedure (QCOS

0210-10} (EEI 06)

We Agree With This Finding

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! Inadequate 50.59 Safety Evaluation

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Causes

j Insufficient Research by the Preparer and

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Reviewer to Identify All Requirements

>> Xo Direct Tie From Applicable UFSAR Sections

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Inadequate 50.59 Safety Evaluation

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Corrective Actions

The Pressure Test Procedure, QCOS 0210-10, Has Been Retired

System Engineering Supervisor Discussed This Finding and

Expectations for Ad. equate Research With Qualified 50.59

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Training Will Be Conducted for 50.59 Preparers and Reviewers

on This Finding and Other Identified Weaknesses. This Will Be

Completed by March 31,1998

Engineering Assurance Group Will Perform Reviews on

Selected 50.59 Screenings Until Effectiveness Is Assured

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Inadequate 50.59 Safety Evaluation

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Corrective Actions (Cont.)

Applicable Sections of the UFSAR Are Being Revised to

Reference Appendix G. This Will Be Completed by January 31,

1998.

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Inadequate 50.59 Safety Evaluation

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Safety Significance

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Lack of an Adequate 50.59 Is a Significant Issue

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Code Pressure Test

XRC Inspection Finding

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Missed or Inadequate Completion of ASME l

Code Section XI Class 1 and 2 Pressure Test -

Five Examples (EEI 03)

>> We Agree With This Finding

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l cgngh! Missed or Inadequate -

Code Pressure Test

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l Examples of the Finding Are:

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Incomplete VT-2 Inspection of Unit 2-Reactor Head

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Failure to Perform Adequate VT-2 (Use of Leak

Detection System) of Unit 2 Reactor Vessel Flange

Failure to Perform Adequate VT-2 (Use of Leak

Detection System) of Unit 1 Reactr Vessel Flange

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Failure to Perform Class 2 Pressure Test of Unit 1

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Head Flange Leak Detection System

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Failure to Perform Class 2 Pressure Test of Unit 2

Head Flange Leak Detection System

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Code Pressure Test

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Incomplete Inspection

- Poor Judgment on Part ofIndivklual Who Inspected the  ;

Reactor Head and Harsh Environmental Conditions l

- Belief That the Leak Detection System Did Not Ivieet the

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Functional Requirements ofIWA-5243

- Performance of the VT-2 Pressure Test of the Class 2 Portion

of tla Leak Detection System Was Not Captured in

Procedures or Predefines a

Ineffective Self Assessment

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Code Pressure Test

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Corrective Actions

Pressure Test of Unit 2 Will Be Performed Prior to

Taking the Reactor Critical

Unit 1 Leak Detection System Was Inspected at 700

Psig

Procedure Has Been Revised to Specifically Require

Walking Around Reactor Vessel Head and Opening the

Access Ports in the Insulation Wall to Perform the VT-2

Inspection Methods Now Require Individual

Acknowledgment of Each Inspection Location As They

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M-issed or Inadequate

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Code Pressure Test

Corrective Actions (Cont.)

VT-2 Examiners Have Been Retrained on Specific  ;

VT-2 Requirements

Q&SA Will Overview Next Class 1 System Pressure

Test

>> Corporate ISI Assessment of Quad Cities Program

(January 5 - 16)

Corporate Pressure Test Assessment (November 18 -

January 16)

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M-issed or Inadequate

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Code Pressure Test

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Corrective Actions (Cont.)

Independent Industry Expert Assessment of Pressure

Test and ISI Programs (November 18 - January 16)

All Assessments at Quad Cities Will Be Completed

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and Issues Appropriately Dispositioned Before Taking

the Respective Reactor Critical

All Identified Issues Will Be Shared With Other

Comed Sites

) Identified Issues at Quad Cities Will Be Resolved Prior

to September 1,1998

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M.issed or Inadequate

Code Pressure Test

Documentation Issues

No Sign Off for Reactor Head Inspection

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- Procedural Omission

>> Programmatic and Procedural Deficiencies Caused the

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- VT-2 of Class 2 Leak Detection System Not Incorporated

l Into Implem~enting Procedures

Procedural Steps Were Completed After Exiting the

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Drywell From the Class 1 Test

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95E9d, Missed or Inadequate -

Code Pressure Test

Corrective Actions for Documentation Issues

Reactor Head Sign Off Has Been Included

All Pressure Testing Procedures Will Be Reviewed

for Omissions and Errors Prior to Use, or by

September 1998, Whichever Occurs First

Management Expectations for Procedural Adherence

to Assure Safety Will Be Reinforced

The Class 1 Test Procedure Now Requires Individual

Sign Offs As Inspections Are Performed

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l Code Pressure Test

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Significance

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These Programmatic Deficiencies Are a Significant

l Issue

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Opportunities to Identify

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Apparent Violations Earlier

In November 1997, Station Management

Discovered, That in July 1997, an Individual Felt l

That One Example of an Inadequate Inspection  !

Existed

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This Has Been Discussed With the NRC Staff Earlier

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Adequacy of VT-2 Inspections

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Unresolved Item Regarding How All Accessible

Surfaces and Insulation Joints of Class 1 Piping

VT-2 Examinations Were Completed in the

Elapsed Times Noted

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The Station Has Determined That These

Inspections Were Not Adequate

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l Adequacy of VT-2 Inspections

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Corrective Actions

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Pressure Test of Unit 1 and Unit 2 Will Be Performed

l Prior to Ta(ing the Respective Reactor Critical

This Finding Will Be Included As Part of the

Comprehensive Assessments Currently Being

Performed. Additional Corrective Actions Will Be .

Included As Part of an Overall Improvement Plan

i Developed From These Assessments

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Corporate Assessment and VT

l Inspection Program

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John Hutchinson

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l System Material Manager

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A Ur.icom Company

VT Inspection Program

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Preliminary Assessment Of SPPVT-2-1

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Implementation

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A Review of the Recent L nidentified Leakage on

Startup From Our Lnits

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These Numbers Indicate That VT-2 Program in a

Gross Sense Is Identifying Leakage

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Based on a Review, the Requirements of SPPVT-

2-1 and SPP2-1-0 Are Being Met at the Other

Sites

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Comed Program Assessment

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VT Program Administered by Common

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Procedures SPPVT-2-1 and SPP2-1-0

Inspectors Are Qualified and Certified to

Procedure SPP2-1-0

SPPVT-2-1 Contains Requirements Provided in

IWX 5000

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Comed Program Assessment

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Validation of the VT Pro ~ gram Implementation Is

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Included in a Broader Assessment of Section XI

Implementation Resulting From the Quad Cities

Inspection

Six Site Assessment of the In-Service Inspection

Program Relating to Piping and Supports, Pressure

Testing, and the Repair and Replacement

Programs

Assessment Based on Inspection Procedures

73051,73052,73753,73755 and NUPEG 0800 4s

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A Unicom Company

Comed Program Assessment

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Team Composed of Team Lead, Corporate ISI

Engineer, Q&SA Representative, Plus Industry

Consultants

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Duration of 3 Months Beginning at Quad Cities on .

January 5,1998 and Completing at Zion on March

'

30,1998

-

Focus on Consistency Between Comed Sites and

Comed and the Industry. Full Compliance With

Applicable Regulatory and ASME Code

Requirements 4e

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. . .

~

A Unicom Company

Closing Remarks

Edward S. Kraft, Jr.

Quad Cities Station

Site Vice President

47

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. , , .., Attachment 2

The apparent violations discussed at the predecisional enforcement conferehce are -

subject to further review and subject to change prior to any resulting enforcement action

1. 10 CFR 50.60, " Acceptance criteria for fracture prevention measures to lightwater

nuclear power reactors for normal operation,' requires, in part, that all light-water reactor

plants must meet the fracture toughness requirements for the reactor coolant pressure

boundacy as set forth in Appendix G, ' Fracture Toughness Requirements."

10 CFR 50, Appendix G, IV.2(d), " Pressure-Temperature Limits and Minimum

Temperature Requirements," requires, in part, that pressure tests ar,d leak tests of the

reactor vessel that are required by Section XI, " Rules for inspection of Nuclear Power

Plant Components," of the American Society for Mechanical Engineers (ASME) Code

must be completed before the core is critical.

ASME Code Section XI (1989 Edition, no Addenda), Table IWB-2500-1, " Examination

Category C P, All Pressure Retaining Components,' at item B15.10 required a system

leakage test (lWB-5221) and visual VT-2 examination of the pressure retaining

boundary of the reactor vessel each refueling outage.

Contrary to the above, on or about June 22,1997 the licensee had failed to perform an

ASME Code Section XI leakage test of the reactor vessel prior to core criticality from the

Unit 2 refueling outage.

!

2. 10 CFR 50.59(a)(1), " Changes, tests, and experiments,' states, in part, that a licensee

may make changes in the facility as described in the safety analysis report (currently

referred to as the Updated Final Safety Analysis Report (UFSAR)) and may conduct

tests not described in the safety analysis report, without prior Commission approval,

unless the proposed change or test involves an unreviewed safety question.

l 10 CFR 50.59(a)(1) states, in part, that a proposed change shall be deemed to involve

an unreviewed safety question if the malfunction of equipment important to safety

previously evaluated in the safety analysis report may be increased.

10 CFR 50.59(b)(1) requires, in part, that the licensee shall maintain records of changes

in the facility as described in the safety analysis report and tests pursuant to paragraph

(a) of this section. These records must include a written safety evsluation which

provides the bases for the determination that the chai.ge or test does not involve an

unreviewed safety question.

UFSAR Section 5.2.4.7, " System Leakage and Hydrostatic Pressure Tests" stated, in

part, that system leakage and hydrostatic tests are conducted in accordance with

IWB-5000, " System Pressure Tests."

IWB-5210, " Test," stated, in part, that pressure retaining components shall be visually

examined by the method specified in Table IWB-2500-1, " Examination Category B-P."

The apparent violations discussed at the predecisional enforcement conference are

subject to further review and subject to change prior to any resulting enforcement action

_ _ _ _ _

_ _ _

,,. a.

\

The apparent violations discussed at the predecisional enforcement conference are

subject to further review and subject to change prior to any resulting enforcement action

Table IWB-2500-1, Note 5, required, in part, that the system leakage test (lWB-5221)

shall be conducted prior to plant startup following each refueling outage."

Contrary to the above, the safety evaluation screenings, which provided the bases for

the determination that the change to procedure QCCS 0201-10, ' Reactor Vessel and

Class One Piping Leak Test at Power Operation," (Revision 0, authorized June 3,1997

and Revision 1, authorized on June 6,1997) did not involve an unreviewed safety

question, were inadequate. The evaluation screenings did not address UFSAR Section

5.2.4.7 which stated (by reference to IWB-5000) leakage tests shall be conducted prior

to plant startup following each refueling outage. Specifically the evaluation screenings

stated that the SAR does not define when the visual examination is performed and the

SAR does not describe leak testing of the reactor vessel with the reactor at power. As a

result of these inadequate safety evaluation screenings, operation of Unit 2 was

permitted prior to completing this leakage test which constituted an unreviewed safety

question, since the probability for a loss of coolaat accident had been increased.

3. Quad Cities Unit 1 and 2 Technical Specification 4.0.E " Surveillance Requirements'"

required implementation of the ASME Code Section XI inservice inspection and testing

requirements for Code Class 1 and 2 components.

ASME Code Section XI (1989 Edition, no Addenda), IWB-5210(b), ' System Test

Requirements - Test," stated, in part, that system pressure tests cnd visual

examinations shall be conducted in accordance with IWA-5000 " System Pressure

Tests."

i

a. iWA-5242(a), " Insulated Components," stated that visual examination VT-2 may

be conducted without the removal of insulation by examining the accessible and

exposed surfaces and joints of the insulation. Essentially vertical surfaces of

insulation need only be examined at the lowest elevation where leakage may be

detectable.

IWA-5242(b) stated that when examining insulated components, the examination

of surrounding area (including floor areas or equipment surfaces located

undemeath the components) for evidence of leakage, or other areas to which

such leakage may be channeled, shall be required.

Contrary to the above, on June 22,1997, the licensee failed to perform an

adequate VT-2 inspection of the reactor vessel head area during the ASME

Code Section XI pressure test of Class 1 systems for Unit 2. Specifically, the

VT-2 examination performed failed to include the lower edge and floor areas of

the refueling cavity at radial locations along the vertical insulation wall

surrounding the reactor vessel head. Further, the licensee failed to utilize an

inspection port in this vertical head insulation to perform direct VT-2 inspections

The apparent violations discussed at the predecisional enforcement conference are

subject to further review and subject to change prior to any resulting eniorcemens action

a - )

_ _ _ _ _ _ - _ _ _ _ _ _ _ - .

3

e'

.

The apparent violations discussed at the predecisional enforcement confere"nce are -

subject to further review and subject to change prior to any resulting enforcement action

of the vessel head.

b. IWA-5243, " Components With Leakage Collection Systems," stated that where

leakagos from components are normally expected and collected (such as valve

stems, pump sea's, or vessel flange gaskets) the visual examination VT-2 shall

be conducted bj verifying that the leakage collection system is operative.'

l. Contrrty to the above, on June 22,1997, the licensee failed to perform

an ade.quate VT-2 examination of the reactor vessel head flange joint

during the Unit 2 ASME Code Section XI Class 1 system leakage test.

Specifically, the VT-2 examination performed failed to verify the absence

of leakage from the head flange, as monitored and collected by the

reactor pressure vessel flange seat leakage detection system. Further,

the VT-2 examination failed to verify that this system was operative.

ii. Contrary to the above, on May 3,1996, the licensee failed to perform an

adequate VT-2 examination of the reactor vessel head flange joint during

the Unit 1 ASME Code Section XI Class 1 system leakage test.

Specifically, the VT-2 examination performed failed to verify the absence

of leakage from the head flange, as monitored and collected by the

reactor pressure vessel flange sealleakage detection system. Further,

the VT-2 examination failed to verify that this system was operative.

c. Table IWC-2500, " Examination Category C-H, All Pressure Retaining

Components," required a pressure test (IWC-5221) and VT-2 examination of

pressure retaining boundaries of Code Class 2 systems during each inspection

period.

i. Contrary to the above, as of February 18,1996 (the end of first inspection

period of the third code interval for Unit 1), the licensee failed to perform

l a Code Class 2 system leakage test (IWC-5221 or Code relief PR-02) of

!

the Unit 1 reactor pressure vessel head flange seal leak detection system

within the required codo inspection period. ,

ii. Contrary to the above, as of March 10,1996 (the end of first inspection

yriod of the third code interval for Unit 2), the licensee failed t Nrform

a Code Class 2 system leakage test (IWC-5221 or Code relie 4-02) of

the Unit 2 reactor pressure vessel head flange seal leak dek.,on system

within the required code inspection period.

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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. . . ..

.. .. . . = - .

1

} ),. Attachment 3  !

ATTENDANCE LIST

(Partial)

DATE: JANUARY 9,1998

COMED

S. Perry, BWR Vice President

E. Kraft, Jr., Quad Cities Site Vice President

J. Williams, Project Manager, Nuclear Generation Group

L Pearce, Station General Manager, Quad Cities

D. Cook, Station Manager, Quad Cities

R. Freeman, Site Engineering Manager, Dresden

B. Rybak, Senior Nuclear Licensing Administrator

R. Ruffin, Regulatory Assistant Coordinator, Dresden

G. Contrady, Site Engineer Programs Lead, Byron .

k

G. Perkins, inspection and Testing Group Lead (Acting), Quad Cities

G. Knapp, Inservice Testing Coordinator, Quad Cities

T. Wojcik, Senior Engineer, Quad Cities

M. Plumadore, Design Engineer, Quad Cities

G. Wald, Corporate Communication

'

R. Wychocki. ISI Engineer

D. Evans, Liaison

J, Arnold, Programs Engineer, Quad Cities .

H. Do, ISI Engineer

B. Helfrich, Sr. Counsel-Nuclear

K. Bethard, Regulatory Assurance, Quad Cities

J. Blomgren, S/G & RPV Projects Manager

T. Fuchs, Nuclear Licensing Administrator .

C. Peterson, Regulatory Affairs, Quad Cities

J. Lewarid, Licensing Opemtionc

R. Svaleson, Operations Manager, Quad Cities

J. Purkis, System Engint. ' ing Supervisor, Quad Cities

C. Hebel, Test Director, Quad Cities

J. Hutchinson, System Material Manager

L. Waldinger, Nuclear Oversight Manager

' F. Famulari, Q&SA Manager, Quad Cities

Nf1C

A. Beach, Regional Adininistrator, Rill

G. Grant, Director, Division of Reactor Projects, Rill

J. Jacobson, Deputy Director, Division of Reactor Safety, Rill

. J. Heller, Enforcement Coordinator, Rlll

M. Holmberg, inspector, Rlli

M. Ring, Chief, Projects Branch 1, Rlli

J.' Gavula, Ch!ef Engineering Specialist Branch 1, Rill

K. Walton, NRC Resident inspector, Quad Cities

lilinois DeLartment of Nuclear Safety

R. Ganser, Quad Cities Resident inspector

The Disoatch and R.I. Argus Newscacers

R. Pearson, Reporter

StructuralIntegritv. Associates

P. Riccardella, Consultant

n U