ML19256F472

Forwards Responses to NRC 750828 Ltr Requesting Info Re Mgt Steps to Improve Compliance in Two Major Areas of Violation. Program Initiated to Improve Analysis of Equipment Failures. Reply to App a Withheld (Ref 10CFR2.790)

ML19256F472
Person / Time
Site:	Quad Cities
Issue date:	10/06/1975
From:	Brian Lee COMMONWEALTH EDISON CO.
To:	Knuth D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML19256F405	List: ML19256F412 ML19256F416 ML19256F418 ML19256F419 ML19256F421 ML19256F423 ML19256F425 ML19256F431 ML19256F434 ML19256F441 ML19256F446 ML19256F450 ML19256F472 ML19256F475
References
FOIA-79-491 NUDOCS 7912190190
Download: ML19256F472 (4)

Text

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Dr. Donald Knuth, Director b)jk;j/

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Office of Inspection and Enforcement

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 M, 'Td>

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Subj ect: Response to Non-Compliance Item and Civil Penalty for Quad Cities Units 1 and 2. Operating I.icense Numbers DPR-29 and DPR-30. NRC Docket Numbers .

50-254 and 50-265.

Dear Dr. Knuth:

I Our response to' Appendices A & B of your letter of August 28, 1975, is attached. Specific response to the violations are numbered to correspond with the violations listed in your letter. The reply to Appendix A contains material related to the details of an industrial security plan and should be withheld from public disclosure in accord-cnce :ith 10 CFR 2. MO.

Your letter asked that in addition to the replies to the specific violations, we inform you of the steps which management was taking to improve compliance in the two major areas in which violations were found. In the area of industrial security, Commonwealth Edison has employed a consultant since the Spring 1975, and we are in the process of implementing a number of recommendations he has made to improve our security plans. Specifically, we are in the process of employing a full time security officer for nuclear generating stations. We believe that the addition of this individual will give our security program the atten-tion which it must have to be continually effective.

Although we have elected not to request reduction or remission of any part of the civil penalty which was imposed, we would like to call your attention to Item 4 of Appendix A. It is our belief that this infrac-tion resulted from a conscientious action taken to temporarily remedy a deficiency in the permanent security system and is indicative not of a lack of concern about security matters, but rather of a determination to meet -

all the criteria of 10 CFR 73 as quickly as possible.

With respect to the violations cited in Appendix B, Commonwealth -

has taken a number of actions. At a meeting held on June 4, 1975, between Region III and Edison personnel, a nmber of commitments to improved management control were made, and are being impl emen ted. These commitments were further emphasized at a meeting held on June 2'4, 1975, ber cen Messrs.

Ayers and Behnke of Commonwealth, and Y.eppler and Fiorelli of Region III_.

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.nce that time, Mr. Ayers and other members of Cocmonwealth's top '

,nagement have visited each of our nuclear stations to review the impor- ,

ance of compliance with N!!C regulations with station personnel. We nave initiated a program to improve the analysis and trending of Abnormal Occurrenecs and equipment failures. We also have reviewed our Action Item Lists to concentrate our efforts on the most significant items.

Finally, we have instituted a program which gives personnel errors in our stations the same degree of investigation and analysis which is given to serious accidents.

Comraonwealth Edison intends to take every action necessary to insure that Quad Cities Station is operated in conformance with all NRC regulations and continues to pose no hazard to public health and safety.

Sincerely, fY Y Byron Lee Jr.

Vice President mjt Attach. -

cc: T. G. Ayers W. B. Behnka .

J. G. Keppler P90!1OHlNAL f

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APPEND 1X D .

..EFERENCE:

Augunt 28, 1975 NRC Letter Appendix "B" DISCUSSION OF INFRACTION ITEM la:

Power Operations Procedure OGP 3-1, Revision 1, sets the limits for the -

linear heat generation rate based on General Electric recommendations to avoid fuel failure. On May 21 and 22, 1975, the maximum allowable heat generation rate per these guidelines was excceded as However, the technical specification limit was not a xenon transient.

exceeded.

This event was primarily caused by inadequate communications Following among the a reactor ,

parties involved and insufficient response to alarms.the Nuclear' Engineer had left startup on May 20, 1975, shift personnel to inform him when 700 MWe was reached so that core con-ditions power levels.

could be evaluated in order to determine the course to By the time the than a gross power level should have been specified.

passed due to improper consideration of the xenon tra perienced during startup. .

. 3RRECTIVE ACTION:

it provides for the Nuclear The subject precedure has been revised such that Engineers to supply the shift personnel with a set of maximum a LPRM readings.

actual LPRM reading to the maximum LPRM readings.

Meetings and discussions have also been held with the groups involved, emphasizing the circumstances related to this event, and reiterating their responsibilities while performing their respective jobs.

DATE OF FULL COMPLIANCE:

Full compliance with this infraction was achieved on September 3,1975, with the issuance of Revision 2 to the subject procedure.

DISCUSSION OF INFRACTION ITEM lb:

At the time of this event, a station procedure that formally provided for -

the preparation and approval of control rod sequences for each startup had _

not been implemented.

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i eO_RRECTIVE ACTTON: "

OTP 1600 81, Revision 1, has been issued which provides otation Procedur guidelines and direction for the Nuclear Engineers in the preparation and approval of control rod sequences.

DATE OF FULL COMPT.IANCE:

17, 1975, with Full compliance with this infraction was achieved on June the issuance of the above procedure.

DISCUSSION OF INFRACTION. ITEM 2_: -

Contrary to Station Administrative Procedure 39-3-4, instructions given to the operating staff regarding other than normal operations on the sec shift on May 21, 1975, and the Operating Engineer was offsite. .

CORRECTIVE ACT10ti:

The normal practice of the Operating Engineers is to write information in the Daily Order Dook regarding the rates of power increase and decrease Such practice will beand pre-cautions to be taken for startups and maneuvers.

followed more closely in the future.

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,difications to the co$itrol tod withdcawal sequence will be made as part o che normal activitiesNotification of qualified Nuclear Engineers to m of planned maneuvers, howev'e r, maneuvers including startups.

will be written in the Daily Orders by the Operating Engineer.

The procedure referenced in Item lb above provides fo and should complete the procedural deficiency fulfillment.

s DATE OF FULL COMPLIANCE:

As described above, full compliance is ichieved with this infraction at the present time.

Actions taken or planned at the station to improve the effectiveness of management control as it relates to these items of noncompliance have been in the form of increased participation by the Nuclear Engineers in rod .

maneuvering limits.

in order to maintain the core conditions within ,

operators, emphasis will be placed on the importance of understanding and _

following the procedural controls established to provide for satisfactory These performance.of the reactor core and still maintain its integrity.

actions along with the specific actions described above should improve

'rsonnel performance and serve to prevent occurrences similar to this in e future and thus enhance the management control related to these items of noncompliance. .

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