IR 07100103/2012023

Notice of Violation from Insp on 971103-1223.Violation Noted:Licensee Failed to Promptly Correct Conditions Adverse to Quality & Failed to Take Measures to Assure That Corrective Actions Were Taken

ML20198T495
Person / Time
Site:	Quad Cities, 07100103
Issue date:	01/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198T488	List: IR 07100103/2012023 ML20198T481 ML20198T507
References
50-254-97-26, 50-265-97-26, NUDOCS 9801270073
Download: ML20198T495 (4)

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NOTICE OF. VIOLATION -

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Commonwealth Edison Company Docket Nos. 50 254; 50 265 :

< Quad Cities Station, Units 1 rnd 2 . Lloense Nos. DPR-29; DPR-30

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During an NRC inspection conducted on November 3 through December 23,1997, three violatsons of NRC requirements were identified.. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed -

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l- belo i F CFR Part 50, Appendix B, Criterion XVI, *Conective Action," requires, in part, that j- -

measures be established to assure that conditions adverse to quality are promptly

' identified and conected and that action to preclude repetition be taken for significant i' conditions adverse to qualit Contrary to the above, the licensee failed to promptly correct conditions adverse to qaality and failed to take measures to assure that corrective actions were taken to preclude 4 l, repetition of significant conditions adverse to quality as follows: j i

- Problem identification form (PlF) 96-2154 was generated on June 20,1996, to

• evaluate the susceptibility of Quad Citiec GE 4 kV breakers to problems found at

Dresden. The corrective action for problems identified in this PIF related to -

stiffened lithium grease in Quad Cities 4 kV breakers, and involved changing out .

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all unrefurbished breakers needed for operation within 12 months or perform i additional grease aging studies. These actions were not complete as of i November 19,199 On February 2,1997, closing springs on a safety related 4 kV GE AMH breaker

- failed to recharge due to suspected hardened grease, as documented in PlF 97-0373. Corrective action for the hardened grease condition included t

refreshing the bearings on eight breakers with lubricating oil and replacing them with re'urbished breakers from Unit 2 following the Unit 2 Q2R14 refueling outag However, on November 30,1997,5 months after the end of the Unit 2 refueling i outage, five of the eight breakers were not replaced with refurbished breakers, L and four of these breakers were not lubricated with oil, r

This is a Severity Level IV violation (Supplement 1). , (50 254/97026-01; j -50-265/97026 01) CFR Part 50, Appendix B, Criterion V,? instructions, Procedures, and Drawings,"

states, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be

. acces.p;ished in accordance with these instructions, procedures, or drawings."

-Workers reassembled the high pressure coolant injection steam admission valve -

4- (2-2301-4) using Quad Cities Mechanical Maintenance (QCMM) Procedure 1515-17,-

" Pressure Seal Gate Valve Maintenance," Revision 0, dated November 19,199 Step I.14.d of the' procedure stated, " Install bonnet, pressure seal and bonnet fastener .

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Draw up squarely ensuring seal ring is seated properly."

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Not ce of Violation -2--

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Contrary to the above, on May 30; 1997, maintenance workers installed the bonnet on ,

Unit 2 high pressure coolant injection valve (2 23014) upside dow ,

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This is a Severity Level IV violation (Supplement 1). T (50-265/9702602) Technical Specification 4.0.A states, " Surveillance Requirements shall be met during the j

reactor OPERA TIONAL MODE (s) or other conditions spectred for individual Limiting -

l i Conditions for Operation unless otherwise stated in an individual Surveillance Requirement."

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Technical Specification 4.0.D states, " Entry into an OPERATIONAL MODE or other -- ,

-- specified apphcable condition shall not be made unless the Survolence Requirement (s) y

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associated with the Limiting Condition for Operation have been performed within the _

applicable surveillance interval or as otherwise specified. This provision shall not prevent - ,

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passage through or to OPERATIONAL MODE (s) as required to comply w!th ACTION

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. statements." Technical Specification Table 3.2.E-1 requires that the average power range monitor (APRM) down scale control rod block be operable in MODE Technical Specification Table 4.2.E-1 requires a channel functional test of the APRM down scale control rod block within 7_ days prior to startup [ MODE 2] and

- monthly while in MODE 1.

' Technical Specification Table 3.1.A-1 requires that two operable channels per trip systemior the Reactor Protection System (RPS) Instrumentation APRM Flow Biased High Neutron Flux Trip be operable in MODE Technical Specification Table 4.1.A-1 requires a weekly channel calibration of the C RPS instrumentation APRM flow biased high neutron flux trip while in MODE 1 and that the calibration shall consist of the adjustment of the APRM flow biased

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channel to conform to a calibrated flow signa Technical Specification Table 3.2.F-1 requires that two operable channels of torus

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pressure instrumentation be operable in MODES 1 and 2.

$ Technical Specification Table 4.2.F-1 requires a monthly channel check of the torus pressure instrumentation in MCDES 1 and Contrary to the above,

. The channel functional test for the APRM down scale control rod block was not performed within 7 days prior to startup when Unit i entered MODE 1 on ,

March 17,29, and April 24,1997, and when Unit 2 entered MODE 1 on June 21 1997.-

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Notice of Violation . 3-

4 ' (1) - The channel calitxation for the RPS instrumentation APRM flow biased high neutron flux trip was not performed prior to entering MODE 1 for -

Unit 1 on March 17,1997. -

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, l (2) The channel calibration for the RPS instrumentation APRM flow biased -

high neutron flux trip was not performed prior to entering MODE 1 for Unit 2 on June 21,1997, and was not performed weekly as required until July 22,199 ,

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e (3) The channel calibration for the RPS instrumentation APRM flow biased high neutron flux trip was not performed within the required weekly '

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frequency with Unit 1 in MODE 1 on December 16,199 The channel check for torus pressure instrumentation was not performed prior to '

i' entering MODE 2 for Unit 1 on March 28,1997, and for Unit 2 on June 8,199 This a Severity Level IV violation (Supplement I) (50-254/97026-03; 50-265/97026-03)

' 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 Comn4nion, ATTN:

Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region lil, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for L each violation: (1) the reason for the violation, or, if contested, the basis for disputing the

[ violation, (2) the corrective steps that have been taken and the rer,ults achieved, (3) the

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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 ,

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correspondence, if the correspondence adequately addresses the required response, if an

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adequate reply is not received within the time specified in this Notice, an order or a Demand for

Information may be issued as to why the license should not be taken. Where good cause is shown, consideration will be given to extending the response tim The NRC has concluded that information regarding the reason for the violation of

.l -Tec,hnical Speciif cati on 4. .0 D (Violation No. 3), the corrective actions taken and planned to

correct the violation and prevent recurrence and the date when full compliance was achieved

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is already adequately addressed on the docket in Licensee Event Reports 50 254/265-97023,

[ 50 254/265-97025, and 50 254/265-97026, dated November 23,1997, December 5,1997, and l December 19,1997, respectively. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein_does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your

response as " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory ,

Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the

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Regional Administrator, Region lil, 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 le*ter transmitting this Notice of 1 Violation (Notice).

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Notice of VNMilon -4

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Because your response will be placed in the NRC Public Document Room (PDR), to the extent- ,

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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 yw response that identifies the information that should be protected and a redacted copy of your .

= resoonse that deletes such information. If you request withholding of such material, you mutt specifically identify the portions of ywr response that you seek to have withheld and provide in -

. detail the bases for your claim of withholding. if safeguards information is necessary to provide

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an acceptable response, please provide the level of protection described in 10 CFR 73.21. -  !

Dated at Usle, Illinois this 21st day of January,1998  ;

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