IR 07100027/2011021

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Notice of Violation from Insp on 971027-1121.Violations Noted:As of 971027,local Manual Operation of HPCI Sys, Activity Affecting Quality,Could Not Be Performed in Accordance W/Written Procedure Qcop 2300-08
ML20202G279
Person / Time
Site: Quad Cities, 07100027  
Issue date: 02/13/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202G241 List:
References
50-254-97-22, 50-265-97-22, NUDOCS 9802200099
Download: ML20202G279 (3)


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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50 254; 50 265 Quad Cities Station, Units 1 and 2 License Nos. DPR 29; DPR 30 During an NRC inspection completed on November 21,1997, four violations of NRC requirements were identified. In accordance with the " General Statement of Polley and Procedure for NRC Enforcement Actions," NUREG 1600 (60 FR 34381t June 30,1995), the violations are listed below:

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10 CFR 50, Appendix B, Criterion V, ' Instructions, Proce6 res and Drawings," regulres that activities affecting quality shall be prescribed by documented procedures of a type approp^'e to the circumstances and shall be accomplished in accordance with these proceo a es.

A.

Contrary to the above, as of October 27,1997, local manual o;. oration of the High Pressure Coolant Injection (HPCI) system, an activity affecting quality,

could not be performed in accordance with its w tten procedure QCOP 2300-08, e

"HPCI Local Manual Operations," Revision 10. Specifically, the procedure steps l

to rapidly open Unit 1 and Unit 2 HPCI steam isolation valves MO 1(2) 23014 could not be performed because the steps instructed operators to place jumpers between terminals that did not exist.

This is a Severity Level IV violation (Supplement 1).

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Nuclear Station Work Procedure No. NSWP A 04,"10 CFR Safety Evaluation

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Process," stated, in part, that previously performed screenings can fulfill the screening requirement provided they meet the validation criteria of Exhibit H,

' Validation of Previously Performed Safety Evaluations and Screenings," to determine if the existing screening remains valid.

Contrary to the above, (1)

The 10 CFR 50.59 screening approved on January 26,1996, for temporary alteration No. 961-005, " Fine Tune HPCI Flow Controller at Direction of System Engineer," an activity affecting quality, evaluated the installation of a recorder to monitor six (6) HPCI process parameters.

However, the work request that installed the recorder also Installed additionalinstrumentation. This instrumentation was not evaluated by Exhibit H to determine if the existing screening remained valid.

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The 10 CFR 50.59 screening approved on February 28,1996, for temporary alteration No. 961063, " Connect Chart Recorder to HPCI Oil Pressure Switches to Monitor Pressure during Q1R14," an activity affecting quality, evaluated the installation of a recorder to monitor HPCI process parameters. However, the work request that installed the 9002200099 900213

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Notice of Violation

i rtcorder also installed additionalinstrumentation. This instrumentation was not evaluated by Exhibit H to determine if the existing screening remained valid.

This is a Severity Level IV violation (Supplement 1).

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Quad Cities procedure NSWP A 04, Rev. O, *10 CFR Safety Evaluation Process," Section 5.4.1.3 states, in part, that the report to the NRC shall contain a brief description of each change, test, or experiment and a summary of the safety evaluation performed.

Contrary to the above, on '"'y 1996 and October 1997 the 10 CFR 50.59 su mary repoos subn.

s the NRC contained only those 50.59 descriptions that changed the Updated Final Safety Analysis Report (UFSAR) and not a description of each change, test, and experiment performed at the facility.

This is a Severity Level IV violation (Supplement 1).

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10 CFR 50, Appendix B, Criterion 111," Design Control," requires, in part, that design control measures assure that the design basis for structures, systems, and components are correctly translated into specifications.

Contrary to the above, as of November 12,1997, Modification M041(2)-91013, * Modify Break Detection Logic to Prevent Spurious isolation of HPCl " an activity affecting quality, did not address the additional alternating current (AC) inboard isolation valve closure time during a loss of offsite power event. As a result, the overallinboard isolation valve closure time was not reviewed against the ulve's design basis time assumed in the Updated Final Safety Analysis Report.

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply si ould be clearly marked os a * Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for

!nformation may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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Notice of Violation

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If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555 0001.

Because your responce will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information, if you request withholding of such material, you muni specifically identify the portions of your response that you seek to have withheld and provide in

. detall the bases' for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information), if safeguards information is necessary to provide an acceptable response, please

_ provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 13th day of February 1998

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