ML19354E859

Responds to NRC 891128 Ltr Re Violations Noted in Insp Repts 50-254/89-17 & 50-265/89-17.Corrective Actions:Procedure NSWP-E-01, Electrical Cable Installation Insp, Will Be Revised to Enhance Human Factor Aspect

ML19354E859
Person / Time
Site:	Quad Cities
Issue date:	01/16/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0504T:1, 504T:1, NUDOCS 9002020094
Download: ML19354E859 (14)

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• Commonwealth Edloon y- One First Nationa' Plaza Chicago Illi.wis

. Address Reply to; Post Off5IBoy 767

. Chicago, Ilknois 60690 07G7 January 16, 1990.

Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission ,

Region III 799 Roosevelt Road Clen Ellyn, IL 60137

Subject:

Quad' Cities Station Units 1 and 2 Response to Notice of Violation Contained in Inspection Report Nos. j IR 50-254/89017 and 50-265/89017 HRC_l)ncket Nos. ~ 50-254 and 50-265

Reference:

Letter from H.J. Miller to Cordell Reed dated November 28, 1989 transmitting IR Nos.

50-254/89017 and 50-265/89017.

Mr. Davis: '

i The referenced letter transmitted the results of the Maintenance Team-Inspection which included two (2) Notices of Violation (NOV). Attachment A to this letter provides Commonwealth Edison Company's (CECO) response to the subject Notices of Violation. The NOV cited examples in which personnel did not follow procedure, inadequate procedures, and failure to implement l appropriate corrective actions. CECO understands the_ significance of the issues involved and the need for effective corrective actions to prevent recurrence.

Attachment B provides an overview of significant improvement, programs which are currently underway at Quad Cities Station. Ceco appreciaten the NRC's efforts in'their review of the Quad Cities Maintenance Program nnd the 3 goal of these programs relate directly to strengthening the Qund cities i Maintenance Program. A request for extension was requested and subsequently-granted by F. Jablonski of your office.

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ADOCK 05000254 O PDC ]/jI . ,

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A.B. Davis -:2 - 1 January 16, 1990 If there are any questions or comments regarding this matter, please.

contact this office.

Very truly yours,

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T.J ovach-Nuclear Licensing Manager im Attachment i

i cct T.M. Ross - Project Manager, NRR J.M. Hinds - Region III J

R.L. Higgins - Senior Resident Inspector, Quad Cities F.J. Jablonski - Region III .

J.H. Neisler - Region III

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1 ATTACIBRENT A RESMNSE TQ_HOTICE OF VIOLATION.

IR 50-254/890171 50-265/89017

1. 10 CFR 50, Appendix B, criterion V, as described in Section 5 of Topical Report CE-1A, Revision 55, and as implemented by Quality Assurance Manual, Section 5, requires that activities affecting quality be prescribed by-documented instructions, procedures, and drawings, and that those activi-ties be accomplished in accordance with those instructions, procedures and drawings. Criterion V further requires that Instructions, procedures, or drawings shall include appropriate quantitative or. qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished..

1 Contrary to the above:

a. The licensee failed to follow the acceptance criteria of Quad Cities Nuclear Station Work Procedure NSWP-E-01, " Electrical Cable i Installation and Inspection," Revision 1, for calculating the maximum allowable pull tension of electrical cables. This procedure, based on -j the vendor cable pulling criteria, stated that the maximum pulls shall ,

not exceed either the maximum pull tension or a tension to be calculated on the basis of the sidewall pressure' factor and the radius i of the conduit bend. This resulted in a contractor specifying higher )

than allowable pull tensions in two work packages.  !

Work Package Q 69856 specified a maximum cable pull of 3165 lbs.

instead of 4671bs.; Work Package Q 69854 specified a maximum cable 1 pull of 7000 lbs. instead of 1558 lbs.- This did not result in any l cable pulls in excess of the revised allowable' cable pulls in those-two cases. The vendor's formula for calculating maximum allowable cable pulls was not utilized for most of'the licensee's cable pulls ,

made during plant outages in 1987-and 1988. The licensee was asked to '

investigate these cable pulls to verify acceptability of pulls to verify acceptability of pull. tension and to .take corrective actions as necessary.

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b. Quad Cities Procedure-QMMS 6600-1-S4, " Diesel Inspection - Refueling Outage Checklist,". Revision 2, did not include the acceptance criteria for the diesel overspeed trip test. The checklist, which was-used for j the tests on Unit 1/2 (common) on May 7, 1988, and on Unit 2 on June 9, H 1988 had no provision to document the as-found overspeed trip setting j of the diesels. As a result, the as-found trip settings on some j previous tests could not be verified. 1 i

c. Quad Cities Procedure QOS 2300-7, "HPCI Turbine Overspeed Test,"

Revision 3, did not include an acceptance criteria for the overspeed; trip test. As the overspeed . trip test results could not be verified for several years of operation prior to 1986, it was not evident i whether the test results were within the acceptable limits.  ;

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d. Quad Cities Procedure QOS 2300-7, "HPC11 Turbine Overspeed Test,"

Revision 3 had no provisions to document either the as-found overspeed trip setting of the HPCI turbine or dates and signatures by the QC/QA inspector and test engineer. As-found trip settings could not be traced for tests conducted prior to-1986 and the results:of tests conducted between 1987 and 1989 could only be obtained'from the operators logs.

This is a Severity Level IV Violation.

EXAMPLE (a)

The licensee failed to follow the acceptance criteria of Quad Cities Nuclear Station Work Procedure NSWP-E-01, " Electrical Cable Installation and Inspection," Revision 1, for calculating the maximwn allowable pull tension of electrical cables. This procedure, based on the-vendor cable pulling criteria, stated that the maximum pulls shall not exceed either the maximum pull tension or a tension to be calcu- lated on the basis of the sidewall pressure factor and the radius of the conduit bend. This resulted in a contractor specifying higher than allowable pull tensions.in two work packages.

1 Work Package Q 69856 specified a maximum cable pull of 3165 lbs. instead of 4671bs.; Work Package Q 69854 specified a maximum cable pull of'7000-lbs. instead of 1558 lbs. This did not result in any cable pulls in excess of the revised allowable cable pulls in these two cases. The vendor's formula for calculating maximum allowable cable pulls was not utilized for most of the licensee's cableLpulls made during plant outages.

in 1987 and 1988.- The licensee was asked to investigate-these cable. pulls-j to verify acceptability of pulls to verify acceptability of pull tension  ;

and to take corrective actions as necessary.

ACTIONS TAKEN TO CORRECT THE DEFICIENCY  !

1. A review was performed on all work requests which involved cable pulls through conduit during the Unit 1 Refueling Outage to ensure that the-maximum pull tension was properly calculated. The review was-accomplished during. utilizing NSWP-E-01, Electrical Cable Installation.

and Inspection, Revision 1. The review revealed that work requests contained the accurate maximum allowable pull tensions, i~.e., the maximum copper tension and not the sidewall pressure, with-the excep-'

tion of two cases. Work Requests Q69856 and Q68954 were renined-to reflect the sidewall pressure as the limitinn maximum puu '.s mien.

The activities associated with these work requests had not twen initiated upon discovery of the discrepancy.

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2. A training session was' conducted with the Stone & Webster electrical work planners. The training session reviewed the requirements of NSWP-E-01 and stressed the importance of determining the limiting pull:

tension requirement. This training session was conducted on November 11, 1989.

'l CQl@ECTIVE ACTIONS TO PREVENT FURTHER NONCOMPLIANCE

1. A revision to NSi1P-E-01', Electrical Cable Installation Inspection, will be performed to enhance the human factor aspect-of the procedure-and checklist. -A cable maximum pulling tension / sidewall pressure form will be implemented to ensure that the maximum pull tension and.

sidewall pressure information is documented and readily available, ,

This revision should assure that the importance of sidewall _ pressure in calculating the maximum cable pull tension. This procedure-revision will be accomplished by June 15, 1990.--

In the interim, Stone and Webster wi11' document the maximum pull tension / sidewall pressure values =on a Work Package Supplement Sheet.

The requirement to review the sidewall pressure was not readily identifiable .in the procedure and the required form,: thereby, allowing for the requirement to be overlooked.' j l

2. Procedure QEMP 700-1 will be revised-to incorporate the references of j Electrical Installation Specification NC 0008 and NSWP-E-01. This i will ensure that sidewall pressure and maximum pull tension will be. l

'l calculated. The procedure will be implemented by January 31',- 1990.

3. Finally, an engineering evaluation will be conducted on al1~ electrical cable pulls performed after January 1, 1987. The ovaluation will be performed, as follows:

a. Work requests and modifications involving cable' pulls: within conduit will be identified by February 28, 1990.

b. A data base will be established for.each identified cable pull ,

consisting of the following information: i Cable ID. Number Cable Size and No. of Conductors Number of Other Cables Pulled Cable size and No-. of Conductors for Other-Cables Machine'or Manual Pull  !

Degree of Bend Conduit Size and Type The data base will be implemented for. Unit 2 cablev by Artit 30, 1990, and for Unit 1 cables by December 31, 1990. The completion' id dates were determined based on current Outage schedule.

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c. For each conduit cable pull, an evaluation will be performed to determine if the cable pull'is acceptable based on the available i documentation and current procedures and standards, including both pulling load and sidewall pressure considerations. The evaluation-will be completed on June 30, 1990 for Unit 2 and February 28,. .

1991 for Unit 1.- 4 L

d..'A final evaluation report will be issued'on April 30, 1991.-

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

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Full compliance was achieved on November 11, 1989 fo110 wing the completion- i of work analyst training.

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EXAMPLE-(b)

Quad Cities Procedure QMMS 6600-1-S4, " Diesel Inspection - Refueling Outage Checklist," Revision 2, did not. include the' acceptance criteria for the diesel overspeed trip test. The checklist, which was used for the tests on Unit 1/2 (common) on May 7, 1988, andlon Unit 2 on June 9, 1988-had no provision to document the as-found overspeed trip setting of the diesels. 'As a result, the as-found trip settings on some previous tests could not be verified.

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DISCUSSION Procedure QMMS-6600-1-S4 r ;uired that the Test Director review the acceptance criteria specified in the Vendor Equipment Technical Information manual to assure satisfactory completion of the test. .The Test Director would indicate this verificatiot by.his/her initials on QMMS-6600-1-S4, Diesel Inspection Refueling Ot.tage Checklist.

Quad Cities Station concurs that the acceptance criteria for the diesel generator overspeed trip should be included in the procedure to enhance; human factor usability. Also, the speed at which the diesel overspeed trip cccurred should be documented on the checklist.

ACTIONS TAKEN TO CORRECT THE DEFICIENCY Quad Cities Procedure QMMS-6600-1-S4 has been revised to include .

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acceptance criteria for the diesel generator overspeed trip and-the requirement to document the speed at which the overspeed trip occurred.

The procedure revision was implemented in September, 1989.

CORRECTIVE ACTIONS 3AEEN TO PREVENT FURTHER NONCOMPLIANCE The surveillance procedures for the diesel generator will be reviewed to.

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ensure that acceptance criteria is included in the procedure and that as 'l found conditions be documented. The review of the surveillance procedures t will be completed by April 30, 1990. Based on the results of the review, 3 procedure revisions will be implemented, as required. Procedure revisions-will be completed by October 31, 1990. l j

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DATE WHEN DJLL_ COMPLIANCE WILL BE ACHIEVID i Full compliance was achieved in September, 1989 with the impNmentation of the procedure revision to QMMS-6600-1-S4. _j 1

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9 EKMif.LES (c) and (d)'

Quad Cities Procedure QOS 2300-7, "HPCI Turbine Overspeed Test," Revision 3, did not include an acceptance criteria for the overspeed trip test. As the overspeed trip test results could not be verified for several years of-operation prior to 1986, it was not evident whether the test results were within the acceptable limits.

Quad Cities Procedure QOS 2300-7, "HPCI Turbine Overspeed Test," Revision 1 1

3 had no provisions-to document either the as-found overspeed trip setting i of the HPCI turbine or dates and signatures by the QC/QA. inspector and  !

test engineer. As-found trip settings could not be traced for tests

! conducted prior to 1986 and the results of tests conducted between 1987 l

i and 1989 could only be obtained from the operators logs.

DISC 11SS10H Quad Cities acknowledges that Procedure QOS 2300-7. "HPCI Turbine Overspeed Test" does not include the acceptance criteria for the HPCI turbine overspeed trip or require that actual speed be documented.

As indicated in Example (d), there is no provisions in-the procedure for the signature of the QC/QA Inspector or-Test Engineer. Neither Quality Assurance nor Quality Control are required to witness the conduct of every-  !

HPCI Turbine Overspeed. Test and, th2refore, no permanent space in the procedure is provided. Quality Assurance and Quality Control are' required-to review safety-related and regulatory-related work requests. During the.

review of these work requests, the reviewer determines whether a QA/QC Hold or Witness Point is appropriate. The Hold or Witness Peint is incorporated into the work package and a line is drawn for the appropriace signature. The completed surveillance procedure reviewed by.the NRC j Inspector was contained in a work package and Quality Assurance inserted a hold point, however, omitted to drawn a lineito provide.for signature.

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l ACTION TAKEN TO CORRECT THE DEFICIENCY 'd il A revision to procedure QOS 2300-7, HPCI Turbine Overspeed Test, has been implemented to incorporate the acceptance criteria for the the HPCI turbine overspeed trip and to record the as-found trip setting. The.

procedure was revised and issued in November, 1989. The procedure will be l further revised to include provisions for the Test Engineers signature by January 15, 1990.

CDRRECTIVE ACTIONS TAKEN TO PREVENT FURTHER NONCOMPLIANCE Surveillance procedures for the HPCI system will be reviewed to 'msure q 4.

that acceptance criteria is defined, appropriate signature blods are i provided and es found conditions are documented. The revie' ef the '

procedures will be completed on April 30, 1990. Based on the review results, procedure revisions will be implemented by October 31, 1990.  ;

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED j 1

Full compliance will be achieved on January 15, 1990, when the procedure ,

-will be revised to include appropriate signature blocks. 1 0531T:8 l

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2. 10 CFR 50, Appendix B, Criterion XVI,las described in Topical Report CE-1A, Revision 55, and as implemented by Quality Assurance Manual.

Section 16, requires that measures be established to. assure conditions ..

adverse to quality are promptly identified and corrected. In the case of-significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition, and that the significant conditions. adverse to quality, the causes of the condition, and the corrective actions taken are documented and reported to appropriate levels of management.

Contrary to the abovet

a. The licensee failed to document and evaluate non-conforming conditions regarding the installation of oversized fuses during and prior to this inspection, in spite of having resolved an Action Item Request on this subject in 1988 committing to document and evaluate fuse size discre-pancies when identified.- Thus,: the causes of - the nonconforming conditions were not identified and corrective action to preclude recurrence was not' implemented.

b. 1me licensee failed to take adequate corrective action to implement vendor recommended preventive maintenance.to inspect, lubricate, and exercise the RCIC turbine trip valve and linkage even af ter the  ;

subject turbine tripped several times on overspeed in 1986 due to the linkage being out of edjustment.

This is a Severity Level IV Violation. li f3 AMPLE (a)

The licensee failed to document and evaluate non-conforming conditions regarding the installation of oversized fuses during and prior to this  !

l inspection, in spite of having resolved an Action Item Request on this l subject in 1988 committing to document and evaluate fuse size discre-. . j pancies when identified. Thus, the causes of the nonconforming conditions  !

were not identified and corrective action to preclude recurrence was not implemented. jl DISCUSSION During the Maintcaance Team Inspection, the team discovered that a 15 amp fuse had been placed in a RPS circuit in panel 901-15 whi:h t~p!! red a 5 amp fuse. When the discrepancy was discovered, the 15 any f use won removed-and replaced by a 5 amp fuse as required by drawing 40-1503A. revision.

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i The Technical Staff performed an evaluation of'the discrepancy and determined that circuit protection was acceptable on September 21, 1989.-  !

On October 5, 1989 Discrepancy Record (DR) 89-3461 was initiated to document the incorrectly _ sized fuse in panel 901-15.

Action Item Request (AIR) 88-37 has not yet been resolved. Monthly follow-ups are still being conducted to document the status of the issue resolution.

ACTION TAKEN TO CORRECT THE__DISchEPANCY )

The 15 amp fuse was replaced with the required 5 amp fuse. The Tech Staff evaluation concluded that adequate protection was provided for the circuit._ A Discrepancy Report was initiated and an evaluation was performed. ,

CORRECTIVE ACTION TAKEN TO PREVENT FURTHER NONCOMPLIANCE l A review to ensure that properly sized fuses are contained in.the Control Room and Auxiliary Electric Room panels has been initiated. Accessible fuses with readily identifiable fuse sizes have=been verified in the Control Room and Auxiliary Electric Room panels. In order to verify the sizes of the remaining fuses, jumpers will have to be installed and.- 1 l therefore, the remaining fuse sizes will be verified during the 1990 Unit 1 Refueling Outage and the 1991 Unit 2' Refueling Outage. Discrepancies found during this verification will be documented on a Discrepancy Record to ensure that appropriate Engineering Evaluation is provided.

I l DATE WHEN FULL COfiELIANCE WILL BE ACHIEVED i

j Full ccmpliance was achieved on October 5. 1989, with the issuance of the j Discrepancy Record.

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a EKAMPLE_Ihl  !

The licensee failed to take adequate corrective action to implement vendor recommended preventive maintenance to inspect, lubricate, and exercise the .j' RCIC-turbine trip valve and linkage even after the subject turbine tripped several times on overspeed in 1986 due to the linkage being out of adjustment.

DISCUSSIDN The trip / throttle (T&T) valve automatically trips shut on a turbine overspeed and can also be used to throttle steam flow to control turbine speed upon failure of the turbine governor. . Per the. vendor manual for the Reactor Core Isolation Cooling (RCIC) turbine T&T valve, the T&T valve is recommended to be cycled, one-quarter close and opened, once per week.

This weekly exercise is intended to demonstrate that the valve stem is not  ;

binding thereby preventing valve movement. This type of binding is most likely to occur after prolonged operation of the turbine or exposure to high temperatures which could cause thermal binding of the stem or a r breakdown of the lubricant. The RCIC turbine at Quad Cities Station is i not normally operated for prolonged periods. It is exposed to_high temperatures (steam) once per month during normal operability testing which takes approximately 30 minutes. This operation does not expose the T&T valve to any severe stress which could cause binding. Based upon system operation, therefore, a weekly test is not necessary-to assure operability of this valve.

The T&T valve is tested and lubricated once per cycle during overspeed testing of the RCIC turbine. This test-assures operation of the valve

. under actual operating conditions. The valve is used to throttle steam-flow to slowly increase turbine speed to the overspeed. trip setpoint and j then trip closed, under steam flow, when the overspeed setpoint is ,

reached. There has been no problems of binding of the T&T valve during '

any of the overspeed trip tests or at any other time, therefore,_

additional testing is not necessary.

6CTION TAKEN TO CORRECT THE DEFICIENCY  !

Quad Cities Station will contact the vendor representative for the RCIC turbine and inform them of our deviation from'their recommendations. With e their concurrence the VETI Manual for the RCIC turbine and applicable I

j station procedures will be revised to reflect the recommendations of INP0 SOER 89-1. This SOER requires that the station conduct nvarnread trip mechanism freedom of movement. testing. The manual trip el the :le>p or . .;

trip and throttle valve of the steam turbine should be tested n[ter each i scheduled turbine / pump surveillance at a maximum interval of <paarterly'(as recommended by Dresser-Rand) and as needed f or post-maintenance testing.

This test verifies free movement of the trip. device and tappet assembly,.  :

the stop or trip and throttle valve, and any associated linkages to the trip device. The revision to the Vendor Manual will.be completed by March 30, 1990.

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CORRECTIVE ACTIONS TAKEN TO PREVENT FURTHER NONCOMPLIANCE No additional corrective actions are necessary, MIE_.WHEN FULL COMPLIANCE WILL BE ACHIEVED Not applicable-

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ATTACBEINT B IMPROVEMENT. PROGRAM. OVERVIEW Quad Cities Station appreciates the NRC's effort's in the evaluation of the Quad Cities Maintenance Program. The report provided a beneficial review 3 of our progress in strengthening our Maintenance Program since the NRC's lasti review of our Maintenance Program in-April-June, 1988. The report will ,

assist the Station in the' continuing efforts to define and~ devote resources to.

weak areas.

Quad Cities Station acknowledges the weaknesses identified by the NRC-Maintenance Team Inspection. Overall, the weaknesses are consistent with. .

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those identified by our own self-assessment _ activities. Quad Cities,.in response to NRC Inspection activities and our self-assessment activities, is in the process of implementing several= major efforts to improve areas _which do' not meet the performance expectations defined by the Station and Corporate Office. The following provides a brief synopsis of major activities underway at.the Stations ,

• The Technical Staff will continue to increase in 1990. The. current budget provides for a Technical Staff expansion-from 54 to 68 engineers; however, the staffing increases must be implemented in a controlled manner to allow for effective trainingLand to_ minimize-the- )

burden upon the current staff in their assistance of theinew ,  :

engineers. As an interim measure, the Technical: Staff will be )

augmented by' experienced, General Electric System Engineers.-.The <

contracted engineers will assist in the-System Engineer Program 1 development by providing technical guidance and knowledge to-the ';

current staff. The increase in staff should decrease the number'of _

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systems assigned to each engineer, thereby.. allowing for more focused overview of each system.

• The Technical Staff is currently developing an equipment performance, trending program. This program will require periodic reviewJand:

trending of key equipment performance data. Corrective action plans will be required to be developed by-the~ Technical Staff,for system- J

performance deficiencies, if required.

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• The time frame to conduct Quality Assurance audits has been increased:  ;

from 5 to 10 days in response to previous NRC concerns.- The. revised' l time frame should provide for a more effective investigation.of the

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areas audited. The provisions to extend the time frame of'the audit:

to more than 10 days, due to the scope or complexity of.the audit, will remain in place. In addition, the Site 1 Quality-Assurance Group has consolidated.the audit schedule to prevent duplication of effort j- and provide better definition of audit-scope.

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• Quad Cities St'ation'has developed a new,-comprehensive root cause L . analysis program'in order to better. identify problems,' provide more ,

! thorough and effective corrective actions and formalize systems- l L currently in place. The program willialso define the standard of 1 I training in root cause analysis. This pregram will encompass the existing programs. The new progre.m will be' implemented by, March 31.- L 1990.

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• A major-procedure upgrade program continues <to be implemented. The-upgrade program will identify procedure weaknesses similar to those identified'by the Maintenance Team Inspection. .Several milestones, l including the development of'the Writer's Guide, have been achieved.

The 1990 Goals for the Procedure Rewrite Program have been defined:

based on the procedure's impact to plant safety. .Approximately 4300- ,

procedures are anticipated to be rewritten by 1996..

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• Improvements in the control of Contractors have been implemented at' Quad Cities. Station and Engineering and. Construction (ENC) will provide-augmented overview of contractor activities to assure good work practices are demonstrated by the contractors. Additional i l corrective actions have been discussed with the NRC. Staff during'.

Management Meetings conducted on November 9, 1989 and January. 11, 1990.

These programs, in conjunction with the implementation of the Conduct [

of Maintenance, will strengthen our Maintenance Program and Plant Operations.

Quad Cities Station will continue to aggressively pursue the completion of-these programs:in support of our goal to achieve excellence.

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