05000254/LER-1986-007, Responds to NRC Re Violations Noted in Insp Repts 50-254/87-09 & 50-265/87-09 on 870407-09.Corrective Actions: LER 86-007-00 for Unit 2 Will Be Supplemented to Describe More Fully Root Cause,Investigation & Corrective Actions

Responds to NRC Re Violations Noted in Insp Repts 50-254/87-09 & 50-265/87-09 on 870407-09.Corrective Actions: LER 86-007-00 for Unit 2 Will Be Supplemented to Describe More Fully Root Cause,Investigation & Corrective Actions

ML20214S736
Person / Time
Site:	Quad Cities
Issue date:	05/20/1987
From:	Turbak M COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20214S720	List: 05000254/LER-1986-007, Responds to NRC Re Violations Noted in Insp Repts 50-254/87-09 & 50-265/87-09 on 870407-09.Corrective Actions: LER 86-007-00 for Unit 2 Will Be Supplemented to Describe More Fully Root Cause,Investigation & Corrective Actions ML20214S719
References
3098K, NUDOCS 8706090391
Download: ML20214S736 (5)

LER-2086-007, Responds to NRC Re Violations Noted in Insp Repts 50-254/87-09 & 50-265/87-09 on 870407-09.Corrective Actions: LER 86-007-00 for Unit 2 Will Be Supplemented to Describe More Fully Root Cause,Investigation & Corrective Actions

Event date:
Report date:
2542086007R00 - NRC Website

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Address Floply to: Post Omco Box 767 Chicago, INinois 60690 0767 May 20, 1987 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Comunission Region III 199 Roosevelt Road Glen Ellyn, IL 60137 i

Subject:

Quad Cities Station Units 1 and 2 Response to I.E. Inspection Report Nos. 50-254/87009 and 50-265/87009 NRC Docket Nos. 50-254 and 50-265 Reference (a): Letter from J.J. Harrison to Cordell Reed dated April 24, 1987.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by your office during the period April 7-9, 1987, of certain activities at Quad i Cities Station. The referenced letter indicated that certain activities The Comunonwealth Edison appeared to be in violation of NRC requirements.

Company's response to the Notice of Violation is provided in Attachment A.

If you have any further questions regarding this matter, please contact this office.

Very truly yours, h$ -

Operal. ingfPlant

. S. Turb k g Director Licens la Attachment t

ec: NRC Resident Inspector - Quad Cities

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6 ~~'s e ATTACWENT A COfMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted on April.7-9, 1987, and in accordance with the " General Statement of Policy and procedures for NRC Enforcement Actions," 10 CFR part 2, Appendix C (1986), the following violations were identified:

ITEM OF VIOLATION

1. 10 CPR 50, Appendix B, Criterion XVI, as implemented by Commonwealth

' Edison Co. QA Manual Q.R. No. 16, " Corrective Action," requires, in part, that measures shall assure that cause of the condition is determined and

corrective action taken to preclude repetition for significant conditions adverse to quality.

Contrary to the above, the licensee failed to determine the cause and take action to preclude' repetition on the following Licensec Event' Reports.

(LERs):

LER 50-265/86007, LER 50-265/86008, and LER 50-265/86009.

This is a Severity Level IV violation. (50-254/87009-01; 50-265/87009-01). ,

1 DISCUSSION:

LER No. 50-265/86-007, " Failure of the Unit 2 Core Spray Room Cooler Due to Burnt Contacts," Revision 00, indicated that the event was caused by pitting and burning of the contactor contacts but the cause had not been determined. The corrective action for this event was to replace the contactor.

LER No. 50-265/86-008, "2A and 2B Core Spray Subsystems Inoperable Due to Failure of Room Cooler and Diesel Generator," Revision 01 and 50-265/86-009, "2B Core Spray Room Cooler Inoperable Due to Drive Belt Failures," Revision 00, dealt with room cooler belt failures that rendered the associated systems inoperable. Both LERs indicated that the events were caused by normal operational wear of the room cooler belts.

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t CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVRD LER No. 50-265/86-007, Revision.00, Room Cooler contactor failure, is to have a supplemental report written which will describe more fully the root

. cause investigation and the corrective actions taken. Briefly, it appears that the room cooler contactor was pitted and burned due to auxiliary contacts in the contactor cubicle that were hanging up and not allowing the contactor to fully close. This resulted in poor electrical contact that caused the pitting and burning of the contactor described in the LER.

, This auxiliary contact is a common component in all 480 volt motor control j center (McC) contactors throughout the station. The Station has experienced binding of auxiliary contacts in the past. The Station is i compiling a list of problems that have been identified as having been caused by the auxiliary contact and this list will be incorporated into a report that will be submitted to Station Nuclear Engineering Department

, (SNED) for their evaluation. Based on the results of that evaluation,

! appropriate action will be taken.

! LERs 50-265/86-008, Revision 01, and 50-265/86-009, Revision 00 both j indicated that the cause of these events was due to normal operational I

wear of the drive belts. A supplemental report for LER 50-265/86-009 is

} being prepared to further explain the cause and the corrective action j taken. Briefly, it was determined that the problem of broken belts was caused by the drive pulley that was being used. The original pulley l

design was a variable pitch grooved pulley that was causing premature wear j of the cooler drive belts due to a misalignment that developed over time because of the design problem. The room cooler pulleys have been replaced l with a fixed pitch pulley that is expected to eliminate the excessive wearing of the cooler drive belts.

A new procedure is being written to provide additional guidance in processing and controlling of LERs. The procedure will describe the process for investigation, preparation, review and followup of Leks. The procedure will clarify the purpose of the LER investigation and include the types of information to be obtained and possible sources of investigative information. It will also provide instruction on the preparation of the reports, including the format and content of the text.

The procedure will also include guidance for management review and

! approval of LERs prior to submittal to the NRC to assure proper cause and adequate corrective actions are identified.

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CORRECTIVE ACTION TO AVOID PURTHER VIOLATIONS:

The implementation of the procedure will prevent further violations.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The LER preparation procedure will be implemented by July 1, 1987.

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i ITEM OF VIOLATION

2. 10 CPR 50, Appendix B, Criterion V, as implemented by Comunonwealth Edison Co. QA Manual Q.R. No. 5, " Instruction, Procedures, and Drawings," ,

requires that activities affected quality be prescribed by and performed .

per documented instructions or procedures of a type appropriate to the circumstances.

contrary to the above, the licensee did not have a documented procedure

for processing and controlling LERs.  !

i CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED See response provided above to Level IV violation.

J CORRECTIVE ACTION TO AVOID FURTHER VIOLATIONS The procedure being developed in response to Violation 50-254/87009-01; i 4 50-365/87009-01 will address the investigation, determination of corrective action, preparation and review of LERs. The additional guidance provided by this procedure will formalize what is expected from each investigative report. The procedure will also provide instruction for the management review and approval of the LER to assure proper cause and adequate corrective actions are identified.

In addition, the Station is also developing root cause analysis training.

This training will be directed at providing several analysis techniques which can be used for determination of event causal factors. This

training will be given to the personnel responsible for the investigation,

! Preparation, and review of LERs. 'This training will provide additional 4

tools to aid in the determination of root caus of events such that proper corrective actions can be taken.

These actions are intended to prevent further violations.

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

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The LER preparation procedure will be implemented by July 1, 1987.

4 The training program will be developed by July 1, 1987 and the training is expected to be completed by September 1, 1987.

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