ML19354D948

LER 89-023-00:on 891219,identified Deficient Temporary Procedures Which Altered Intent of Original Procedure QAP 1100-7.Caused by Mgt Oversight in Preparation of Tech Spec Change.Temporary Procedures revised.W/900115 Ltr

ML19354D948
Person / Time
Site:	Quad Cities
Issue date:	01/15/1990
From:	Bax R, Lechmaier J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-023-03, LER-89-23-3, RLB-90-010, RLB-90-10, NUDOCS 9001250048
Download: ML19354D948 (5)

Text

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C0fRfR0fMANNbh Etik O ~ ound Cites Nuclear Powe e -... .

22710 206 konue North Cordova,liknois 61242 9740 To!aphone 300454-2241 RLB-90-010 January,15, 1990 U. S. Nuclear Regulatory Commission Document Control Desk'-

Washington DC 20555

Reference:

Quad Cities Nuclear Power Station Docket Number 50-254, DPR-29 -Unit One-Enclosed is Licensee Event Report (LER)89-023,- Revision 00',- for Quad Cities Nuclear Power Station.

This report is submitted in accordance with the requirements of the Code of  :

Federal' Regulations, Title.10,-Part 50.73(a)(2)(1)(B): The licensee shall report any operation or condition l prohibited by the plant's Technical Specification.

Respectfully.

• COMMONWEALTH EDISON COMPANY-QUAD CITIES NUCLEAR POWER STATION R. L. Bax Station Manager

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RLB/MJB/eb Enclosure cc: R. Stols R Higgins- .

INPO Records Center NRC Region III [/p j 7 qt 2533H/0715Z S

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a LICENSEE EVENT REPORT (LER)

Fu @ u Fact 11ty Name (1)

Docket Number (2) _Eane f31 6 na*+ tities' unit one ofsiofofoL21si4 1 lof!0l4 Title (4)- Violation of Technical Specifications Concerning Review of Temporary Procedures Due to Management Oversight in the Preparation and Review of Technical specification Change Event Data fil LER % r (6) maaart Date (7) Other Facilities Involved (B)

Month Day Year Year //, / Sequential Wygger

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/,/,/,

Revision Month Day Year Facilit y Namet . Dggkt.t Numberfs)

/// / Number gy.ad Cities o f E l o f ol el ZLfd_}

11 2 11 e al e al o o12 13 oIo oi1 Ils el o el si al el el I'l OPE NT M THIS REPORT !$ $UBMITTED PUR$UANT TO THE REQUIREMENTS OF 10CFR fCheck one or more of the followine) fil) 4 20.402(b) ,_ 20.405(c) __ 50.73(a)(2)(iv) 73.71(b)

POWER _ 20.405(a)(1)(t) 50.36(c)(1) ._ 50.73(a)(2)(v) _. 73.71(c)

LEVEL 20.405(a)(1)(11)

,_ .__ 50.36(c)(2) _ 50.73(a)(2)(vit) ,_ Other (Specify flo) o 9 o 20.405(a)(1)(tit) 50.73(a)(2)(1)

_ X 50.73(a)(2)(viti)(A) in Abstract

////////////////////////// _, 20.405(a)(1)(tv) 50.73(a)(2)(it) _ 50.73(a)(2)(v111)(8) below and in

////////////////////////// 20.405(a)(1)(v) 50.73(a)(2)(itt) 50.73(a)(2)(x) Text)

LICENSEE CONTACT FOR THIS LER f12)

Name TELEPHONE NUteER AREA CODE John Lechmaier. Technical Staff Enaineer. Ext. 2174 3lcl9 &l El 41 -l 21 21 41 1 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (131  ;

CAUSE SYSTEM COMPONENT MANUFAC- REPORTABLE CAUSE SYSTEM COMPONENT I j/ MANuFAC- REPORTABLE TURER TO NPRDS / TURER TO NPRDS I l l l l l 1 / l l l i l l I l l l I #

l ! l / l l' l l l l l-SUPPLEMENTAL REPORT EXPECTED f141 Expected Month I Day i Yegr Submission lyes fif ves. comolete EXPECTED SURMISSION DATE) l NO l ll l A85 TRACT (Limit to 1400 spaces, i.e. approximately fifteen single-space typewritten lines) (16)

ABSTRACT:

At 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />, on December 19, 1989, Unit One and Unit Two were in the RUN mode at 90 and 89 percent of rated core thermal power, respectively.

QAP 1100-7, Approval and Authorization of Temporary Procedures and Temporary Changes to Permanent Procedures, was found to be in violation of Technical Specification (TS) 6.2.C.1 for Temporary Procedure Changes involving a change in intent. QAP 1100-7 did not require signatures from both the Department Head and  ;

Assistant Superintendent as stated in T.S. 6.2.C.I.

1 The cause of this event was management oversight in the preparation and review of a previous change to T.S. 6.2.C.1. The change mistakenly added the Assistant i Superintendent in the review process when the intent was only to replace the Department Head Review.

QAP 1100-7, T1, and T6 were revised to comply with T.S. 6.2.C.I. This Technical ,

Specification will be revised to match the intent of the previous change. Also, a '

procedure will be implemented to review procedures when a Technical Specification change is implemented.

This report is submitted to comply with the requirements of 10CFR50.73(a)(2)(1)(B). I i

3507H/07182

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e LiffMtif EVENT REPetT f LER1 TEXT CDMTimuaTiou - Fr.rm Rev 2.o FACILITY NAME (1) 00CKtf_NupeER (2) Lta utsaare ts) pane ts)

Year j/// sequential Revision f,,

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f au mr ound cities unit one oIsieIeIo12161s ale l - ei213 - oIo 012 or 01 4 ,

TEXT Energy Industry Identification system (E!!s) codes are identified in the text as (xx]

PLANT AND SYSTEM IDENTIFICATION:

General Electric;- Boiling Water Reactor - 2511 MHt rated core thermal power.

EVENT IDENTIFICATION: Violation of Technical Specifications Concerning Review of-Te4crary Procedures Due to Management Oversight in the Preparation and Review of Technical Specification Change.

A.- CONDITIONS PRIOR TO EVENT:

Unit: One Event Date: December 19, 1989 Event Time:- -1200 Reactor Mode: 4 Mode Name: RUN Power Level: 90%

This-report'was initiated by Deviation Report D-4-1-89-123 RUN Mode (4) - In this position the reactor system pressure-is at or above 825 psig, and the reactor protection system is energized, with APRM protection and RBM interlocks in service (excluding the 15% high-flux scram).

B. DESCRIPTION OF EVENT:

At 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />, on December 19, 1989, Unit One and Unit Two were in the RUN mode at 90 and 89 percent of rated core thermal power respectively.- QAP.Il00-7,~ Approval -

and Authorization of Temporary Procedures and-Temporary. Changes to Permanent Procedures, was determined to be in violation of Technical Specification 6.2.C.I.

This Technical Specification requires that procedures for:1tems-identified in Technical Specifications 6.2.A. and 6.2.B. and any changes to such procedures,shall be reviewed and approved by the Technical Staff Supervisor an Assistant-Superintendent or-the Technical Superintendent, and Department Head. responsible for the activity performed. At least one person approving each of the procedures shall hold a valid senior operator's license _(SRO). In addition, the procedures and changes thereto must have authorization by the Station Manager-before'being i implemented. '

For a Temporary Procedure' Change which alters the: intent of the original. procedure, QAP 1100-7 required the review of the Technical Staff Supervisor and; Department Head or an Assistant Superintendent. . This was not in accordance;with the Technical' Specification' which required both.the _ responsible Department Head and Assistant' Superintendent'or Technical Superintendent. The discrepancy was discov,ered by.a Corporate Office investigative team whlie examining the event" documented in Deviation: Report (DVR) 4-1-89-121, Unit One Turbine Trip Due to High:Rx Water Level-Signal.

Several immediate corrective actions were taken. All of the existing Temporary i Procedures which changed intent. -14 total, were reviewed and signed by the appropriate Department Head ^or Assistant Superintendent. QAP 1100-7, T1, and T6 were revised to comply with the Technical Specifications. Onsite Review (OSR)' 1 89-72 was performed to review the actions required due to the discrepancy between- 1 QAP 1100-7 and the Technical Specifications. These immediate corrective actions -j were all completed on December 19, 1989.,

asC7H/07182 Il i

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LICENSEE EVEnf REPoET f LEtt TEXT CouTIMuATInn Form Raw 2.0 4

FAc!LITY NAME'(1) DOCKET ESBER (2) lea muMars is) Paan f3)

Lij = i' - Year

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j/u/ $ "ti"t /// R'#1$i'"

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/// "r /// u& r h ad citiet Unit One O'lEl01010l 21-&l E Ol0 -

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. TEXT- Energy Industry Identification System (E!!s) codes are identified in the text as [XX]

There were no other structures, systems or components inoperable or degraded at=the start of this event which could have contributed to the event.

C.- ' APPARENT CAUSE OF EVENT:

This event is_being reported in accordance with4 10CFR50.73(a)(2)(1)(B), which requires the reporting of any operation or_ condition prohibited by the plant!s Technical Specifications.

The root cause of this event was management oversight in the development and OSR.

for a change to Technical Specification 6.2.C.1. The' 0SR (87-15) was performed on-June.5~, 1987. The intent of the change was to upgrade the level of procedure review by replacing'the. Department Head with the Assistant Superintendent in the

-review process. However, the Technical Specification change was mistakenly.

submitted with the Assistant _ Superintendent as an additional--reviewer and not a replacement to the Department Head review. When the change was approved and implemented, the existing procedure controlling temporary procedure changes no longer complied with Technical Specification.6.2.C.1. A contributing factor to the 4 event was that no review of existing procedures was made at-the time the Technical Specification was implemented.

D. -SAFETY ANALYSIS OF EVENT: ,

The safety consequences of this event are minimal. The only area of QAP'1100-7 that did not comply with the wording of Technical Specification 6.2.C._1 was the

. review of temporary procedure changes which alteredithe intent of;the original procedures. Although the procedure did not comply with the new Technical-1 Specification, the same technical level of on-site review was maintained, it was  !

not enhanced to meet the new Technical Specification: change.' QAP 1100-7 did comply l

with Technical Specification 6.2.D for temporary procedure changes which did not alter the intent of the original procedure. Likewise, QAP 1100-4, Station  !

Procedure Revisions, at all times complied with the Technical Specifications. -Th i s ' .I procedure covers permanent procedure changes and the addition of new' permanent procedures.

l E. CORRECTIVE ACTIONS: d Once the discrepancy between QAP 1100-7 and the Technical Specifications was discovered, all of the 14 existing Temporary Procedure changes which altered intent-were reviewed and signed.by the appropriate Department Head or Assistant Superintendent. QAP 1100-7, T1, and T6 were revised to comply with the Technical Specifications. Also, OSR 89-72 was performed to review the actions required due

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to the discrepancy. These actions were completed on December 19, 1989.

A change to Technical Specificatioi. 6.2.C. will be submitted to reflect the intent of the original change (NTS 2542008912301). q i

To prevent the recurrence of this type of event, a procedure.will be-implemented that will require a review be performed of procedures whenever a new Technical 4 Specification change is implemented (NTS 2542008912302).

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' L1fthttf EVENT REPGPT fLiti TEXT cDNTimuaTION Form tev 2.0 '

FACILITY NAME (1) DOCKET NUPSER (2) LER NUMBER f6) Pana f31 Year sequential Revision

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i Quad Cities thit ona 0iEl0 1 0 l 0 1 21 61 E Bl9 - 0l2l3 - 010 014 0F 01 4 TEXT. Energy Industry Identification System (EIIs) codes are identified in the text as (XX) .[*

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F. PREVIOUS EVENTS: .

t A review of past DVR's and Licensee Event Reports (LER's) revealed one related .i documented event in the last five years.: -

DVR 4-1-88-087' .Fallure to Perform CO2 Hosereel Surveillance in Accordance.

.With the Technical Specifications For Fire Hose Stations Due'to '

, .0versight in Technical-Specification Creation.

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! G. COMPONENT FAILURE DATA: .

There was'no component failure identified-in this event. '

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