IR 05000254/1998015

Insp Repts 50-254/98-15 & 50-265/98-15 on 980721-24.No Violations Noted.Major Areas Inspected:Aspects of Licensee Corrective Actions & Engineering Involvement in Corrective Actions Process

ML20236V877
Person / Time
Site:	Quad Cities
Issue date:	07/31/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236V872	List: IR 05000254/1998015 ML20236V870
References
50-254-98-15, 50-265-98-15, NUDOCS 9808040262
Download: ML20236V877 (10)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket Nos- 50-254;50-265 I License Nos: DPR-29; DPR-30 Report Nos: 50-254/98015(DRS); 50-265/98015(DRS)

Licensee: Commonwealth Edison Company Facility: Quad Cities Nuclear Power Station Units 1 and 2 Location: 22710 206th Avenue North Cordova,IL 61242 Dates: July 21-24,1998 Inspecto D. Schrum, Reactor Engineer Approved by: R. N. Gardner, Chief, Engineering Specialists Branch 2 Division of Reactor Safety I

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EXECUTIVE SUMMARY Quad Cities Nuclear Power Station, Units 1 & 2 NRC Inspection Reports 50-254/98015; 50-265/98015 This inspection reviewed aspects of licensee corrective actions and engineering involvement in the corrective action process. The inspector concluded that the licensee was effective in implementing corrective actions to notices of violation and licensee event reports for the specific items reviewed. In addition, the engineering staff was knowledgeable and involved in the corrective action process for the specific item Enginwnna Corrective actions and root cause analyses were acceptable (all sections).

System engineering involvement in the corrective action process was good for the specific items (all sections).

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l Reoort Details l lli. Engineering l

The inspection included a review of the licensee's corrective actions and engineering involvement in the corrective action process. The inspector determined that the licensee was effective in implementing corrective actions to notices of violation cd licensee event reports for (

the specific items reviewed. The engineering staff was knowledgeable and involved in the '

corrective action process for the specific item E8 Miscellaneous Engineering issues (IP 92903, IP 92700)

E (Closed) Violation 50-254/265/96016-01: This violation identified a concern with the protection of motor operated valves (MOV) during a postulated control room fire leading to a hot short. The licensee modified 59 valves to eliminate hot shorts. In addition, the '

licensee evaluated and concluded that 55 other valves were not susceptible to damage or safe shutdown (SSD) procedure revisions were made to mitigate the affects of a fire induced hot short. This violation is considered close j E8.2 (Closed) Licensee Event Reoort (LER) 96011: This LER identified conditions where MOVs could be damaged by hot shorts during a fire. This issue was documented in I Inspection Report 50-254/265/96016. See closed Violation 50-254/265/96016-01 I (above) for corrective action details. This LER is considered close E8.3 (Closed) Licensee Event Reoort 92005-01: This LER was issued in response to a Standby Gas Treatment System (SBGTS) engineered safety feature (ESF) actuatio The actuation was due to a fuel pool radiation monitor bypass switch that was dislodged i during maintenance work on the 902-2 panel. The radiation monitor bypass switch fell l causing a short circuit that blew the radiation monitor upscale trip relay fuse. This led to the initiation of the "A" train of Standby Gas Treatment System and isolation of the

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reactor buildirig ventilation system. The root cause of this event was a failure of the ,

bypass switch mounting bracket due to vibratio )

l Work Request 097614 was written to repair the seismic mountings for the bypass switch. As part of the corrective actions, the bracket screws for the bypass switch were i checked for tightness on a monthly basis during surveillance testing. The safety ecosequences of tKs event were minimal. Revision 1 to LER 92-005 was issued to retract the commi+. ment to perform a modification to move the bypass switches off of the 902-2 panel. No problems had been noted with the bracket since 1992, so the modification was canceled. The inspector agreed with this action. This LER is considered close E8.4 (Closed) Licensee Event Reoort 94003: The licensee identified that a required continuous fire watch was not established when the % motor generator set water curtain was taken out of service (OOS). At the time, Unit 2 was shutdown with the Unit 2 emergency diesel generator OOS. As a result, an hourly compensatory firewatch was in place. However, Quad Cities Administrative Procedure (OCAP) 1500-2," Administrative l l

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Requirements for inoperable Safe Shutdown Equipment," required a continuous fire watch be established as a result of these components being simultaneously OO Following the identification of this problem, a continuous fire watch was established as a compensatory measurc.. This event had limited safety significance because of the low amounts of transient combustibles in the ares and the fact that an hourly fire watch had been assigned to the area. The inspector determined that the licensee's corrective l actions included training the staff on administrative requirements, enhancement of administrative procedures, and revision of the OOS procedure to provide detailed guidance regarding the review of OOS for impact on SSD paths. This LER is  ;

considered close '

E8.5 (Closed) Licensee Event Reoort 94013: The licensee identified that the relays that control the heating, ventilation, and air conditioning (HVAC) for the emergency diesel generators (EDGs) could be impacted by a single fire in a single zone of the turbine building. This was an unanalyzed condition for safe shutdown during a fire. However, this design problem had limited safety significance because the licensee had adequate time to take compensatory measures to cool the diesel generator rooms. The failure to assure that applicable design requirements were met is a violation of 10 CFR Part 50, Appendix B, Criterion Ill. This non-repetitive licensee identified and corrected violation is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-254/98015-01(DRS); 50-265/98015-01(DRS)).

The licensee performed a modification, exempt change E04-094-208, to correct this problem by installing a bypass switch on the Unit 1 EDG HVAC system. In addition, Quad Cities Appendix R Procedures (QARP) 700-1 and 1300-1 were revised to address the actions to be taken for a fire in the central turbine building. However, recent changes to the SSD procedures take credit for the station blackout (SBO) diesel generators and not the EDGs. As a result, the EDG HVAC system is no longer necessary for SSD during a fire. This LER is considered close E (Closed) Violation 50-254/265/97022-04a: This violation was withdrawn as indicated by a letter sent to the licensee on April 9,199 E (Closed) Violation 50-254/265/97022-04b: Temporary Alteration (TALT) No. 96-1-063 installed test equipment on the Unit 1 High Pressure Coolant injection (HPCI) System to record various parameters during surveillance testing. The 10 CFR 50.59 screening approved on February 28,1996, described the change as the connection of a strip chart recorder. The screening stated that the recorder would be the only interface with the affected instrument loops. . Recorder failure modes (open/ shorts) were addressed in the l screening. The inspectors noted that Work Request Task 950084936-01 also installed l

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three (3) Validyne pressuie sensors. However, the original screening did not evaluate the physicalinstallation and failure modes of the additional instrumentation as required j by Nuclear Station Work Procedure NSWP-A-0 The licensee's investigation determined the root cause to be a programmatic weakness in the implementation of the 10 CFR 50.59 process. The licensee's corrective actions included training for the preparers and reviewers of safety evaluations. A 50.59 safety

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i evaluation responsibilities document was issued to all qualified preparers and reviewer In addition, Modifications and Lessons Learned Training was provided that addressed j logic changes associated with design changes. An inspector review of Problem

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Identification Forms (PlFs) identified no recurrence of this problem. Therefore, the l

licensee corrective actions were considered effective. This violation is close E (Closed) Violation 50-254/265/96010-02a: This violation was issued for not properly implementing procedures related to control of temporary alterations. Specifically, temporary alterations greater than three months old were not reviewed, as required, to ;

assure continual applicability of the original safety evaluatio j The licensee's corrective actions included enhancement of Quad Cities Technical Procedure (OCTP) 1020-2, " System Temporary Alteration Review," The inspector verified that all temporary alterations greater than three months old had been evaluated ]

for continued applicability of the safety evaluation. In addition, temporary alteration removal plans were documented and current. There was no recurrence of this proble This item is considered close E8.9 (Closed) Violation 50-254/265/96010-02b: The inspectors identified that required three l

month reviews had not been signed for approval by the technical staff supervisor for '

temporary alterations 94-2-34,94-1-84, and 94-1-12 The licensee's corrective actions included enhancement of QCTP 1020-2. The inspector verified that three month reviews had been signed for approval by the technical staff supervisor. There was no recurrence of this problem. This violation is l considered close E8.10 (Closed) Violation 50-254/265/96010-02c: The inspectors identified that although the l monthly report identified temporary alterations in place, including projected removal '

dates, the report failed to identify responsible individuals and temporary alterations which have had limited progress toward resolution as required by QCTP 1020-2. In addition, the temporary alteration coordinator indicated that prior to 1996, monthly temporary alteration reports were not consistently generate The licensee's corrective actions included enhancement of OCTP 1020-2. The inspector verified that the temporary alteration coordinator reported on the status of the temporary alteration program. The report identified responsible individuals and temporary alterations which have had limited progress toward resolution as required by QCTP 1020-2. There was no recurrence of this problem. This violation is close The only weakness noted was that there were still 15 TALTs in the plant that had been installed longer than 3 months. Seven had been in the plant more than a year. Two had been in the plant since 1992.

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X1 Exit Meeting Summary The inspectors presented the inspection results to a member of licensee management at the conclusion of the inspection on July 24,1998. The licensee acknowledged the findings presente The licensee did not identify any items discussed as proprietar !

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PARTIAL LIST OF PERSONS CONTACTED Licensee C. Peterson, Regulatory Affairs Manager NBC K. Walton, Resident inspector L. Collins, Resident inspector R. Ganser, Illinois Department of Nuclear Safety

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INSPECTION PROCEDURES USED IP 92903 Followup - Engineering IP 92700 Licensee Event Reports LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-254/265-98015-01 NCV HVAC Relays for EDGs in Single Fire Zone.

Closed 50-254/265-98015-01 NCV HVAC Relays for EDGs in Single Fire Zone.

50-254/265/96016-01 VIO Protection of MOVs During Postulated Hot Shorts.

96011 LER MOVs Damaged by Hot Shorts.

92005-01 LER SBGTS ESF Actuation.

94003 LER Continuous Fire Watch not Assigned to impairmen )

94013 LER HVAC Relays for EDGs in Single Fire Zone.

50-254/265/97022-04a VIO Violation Withdrawn by a Letter Sent to Licensee on April 9,1998.

50-254/265/97022-04b VIO TALT Not Properly Screened by Safety Evaluation.

50-254/265/96010-02a VIO Failed to address the Continued Applicability of the Safety Evaluation After Three Months.

50-254/' 36010-02b VIO Three Month Evaluations Not Approved by Technical Staff Supervisor.

50-254/265/96010-02c ViO Responsible Individual identification and Progress of TALT Not Maintaine l

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j LIST OF ACRONYMS USED CFR Code of Federal Regulations EDG Emergency Diesel Generator ESF Engineered Safety Feature

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HVAC Heating, Ventilation, and Air Conditioning

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HPCI High Pressure Coolant injection IP inspection Procedure l

LER Licensee Event Report

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NCV Non-cited Violation NRC Nuclear Regulatory Commission NSWP Nuclear Station Work Procedure l OOS Out of Service PlF Problem Identification Form QAP Quad Cities Administrative Procedure QARP Quad Cities Appendix R Procedure l

QCAP Quad Cities Administrative Procedure

! QCTP Quad Cities Technical Procedure i SBGTS Standby Gas Treatment System SBO Station Blackout SSD Safe Shutdown l l

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L l LIST OF DOCUMENTS REVIEWED LER 94013 Relays That Control the HVAC to the EDCs are all in Same Area.

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LER 92005-00 SBGTS ESF Due to Dislodged Fuel Pool Radiation Monitor Bypass Switch Caused by Work on 902-2 Pane LER 92005-01 SBGTS ESF Due to Dislodged Fuel Pool Radiation Monitor Bypass Switch Caused by Work on 902-2 Panel.

! OAA 04-97-12 Audit Report for Fire Protectio QAA 04-97-10 Audit Report for On-Site Review.

!. NTS #265-180-92-005R100 LER 92-005, Rev NTS #254-180-94-01300 LER 94 01 NTS #254-180-94-01301 NTS #254-180-94-01302 NTS #254-180-94-01303  ;

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NYS #254-180-94-00300 Continuous Fire Watch Not Establishe NTS #254-180-94-00301 Train Shift Engine 3rs, Unit Supervisors, and Shift Foreman.

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NTS #254-180-94-00302 Provide Interim Training.

l NTS #254-180-94-00303 Enhance SSD Procedures.

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NTS #254-180-94-00304 Revise OOS Procedur NTS #254-180-94-00305 Management Review of Specialty Trainin NTS #254-180-94-00306 Evaluate Appropriate Procedure Trainin '

NTS #254-180-96-01100 LER 9601 NTS #254-180-%-01002 Violation 50-96010-0 I Quarterly Report on Temporary Alterations - June 199 CAR #04-97-026 Fire impairment Log I PlF #01997-04373 Deficient Fire Impairment Lo OCTP 1020-02, Rev. 3 Evaluation for System Temporary. Alterations in Effect for Greater than Three Month Mod #E04-1-94-208 Unit 1 EDG HVAC Supply Fan (bntrol Circuit Modification.

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