ML20043G942

Notice of Violation from Insp on 891030-900518.Violation Noted:Licensee Corrective Measures Have Not Been Adequate to Assure That Causes of Excessively Leaking Containment Isolation Valves & Penetrations Determined

ML20043G942
Person / Time
Site:	Quad Cities
Issue date:	06/15/1990
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20043G940	List: IR 05000254/1989024 ML20043G942
References
50-254-89-24, 50-265-89-24, NUDOCS 9006210341
Download: ML20043G942 (2)

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NOTICE OF V10LATI0lj Commonwealth Edison Company Docket No. 50-254; 50-265 Quad Cities Nuclear Power Station Licenses No. DPR-29; OPR-30 As a result of the inspection conducted on October 30, 1989 through May 18, 1990 and in accordance with the " General Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the following N

, violations wete identified:

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10 CFR Part 50, Appendix B, Criterion XVI requires in part, that in the case of signiffcant conditions' adverse to qua'ity, measures shall be taken to assure that the cause of the condition is determined and corrective

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action taken to preclude repetition.

10 CFR Part 50, Apcerdix B, Criterion 11 requires, in part, that the licensee inflem6nt & quality assurance program through plant life, for the Quad Cities site, this program is specified in the Commonwealth Edison Company Quality Assurance

- Program Topical Report CE-1-A, Revision 57.

Section 2.2 of the lopical Report states that the Quad Cities Nuclear Station commits to comply with Regulatory Guide 1.33 dated November 1972.

This regulatory guide e

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requires, in part, that the licensee comply with ANSI Standard 18.7-1972.

Paragraph 6.4 of this ANSI standard requires"that a surveillance test e

. program be prescribed to ensure that safety related structures, systems, 3,,

, and. components will operate to keep parameters within normal bounds, or act to place the plant in a safe condition.

It further requires that the A~g

, testing. frequency be established as prescribed by paragraph 5.1.7.

The

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1atter prescribes a. test frequency that_is related to the results of 3

1 reliabilit; analyses, frequency and type of service, or age of system.

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/ Paragraph'S.I.6.1 requires that a maintenance system be developed to maintain safety-related equipment at quality required to perform its 4

intended function; that experience with failed equipment be reviewed,to 1

determine whether a replacement of the same type can be' expected to

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i performitsfunctionreliably;andthatasuitablelevelofconfidencein

=such systems or components be attained by appropriate performance testing.

Con'trary to the above, the licensee's corrective measurea have not been

' adequate to assure that-the causes of excessively leaking cont.inment isolation valves and penetrations were determined and that #0rrectivt

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action was taken to preclude recetition.

As a consequence, the combined leakage for valves and penetrations subject to Type B and C tests have "y

exceeded the 10 CFR 50, Aprendix J Criterion of 0.6 La for every refueling i

C outage of Unit-.1 since 1979, and for Unit 2 since 1974.

In addition, the.

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. licensee has failed to adjust its surveillance test and preventive 4.

maintenance programs to reflect the unreliability of these containment isolation valves to perform their safety function throughout an entire f'

' fuel _ cycle.

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

2.

10 CFR 50.59, Section (b)(1) requires in part that the licensee maintain

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records of changes in the facility... to the extent that these changes

' 'j constitute changes in the facility as described in the safety analysts ey report..~1 It.goes on to state that "These records must include a 1

written safety evaluation which provides the bases for the det,ermination b

that the change, test, or experiment does not involve an unreviewed

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. isafety q0ettion."

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, Contfary to the above:

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l (a). A safety evaluation performed in 1984 to address addition of an i

i 0 ring to the feedwater check valves did not provide an adequate basis for determining that no unreviewed safety question existed.

i Specifically, the safety evaluation did not address the consequences,

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of failure of the 0 ring on the valve's ability to maintain leak l

tightnessi a safety, function of the valve described in USAR section 5.2.2.

Failure of the 0-ring has continued to occur since 1984 and

' L has1resulted in failures of the. valves' local leak rate tests which in' turn have resulted in f ailures of the containment integrated leak 1

t rate tests, iL

!(b) -In 1987 the licensee failed to perform a safety evaluation prior to l

changing the 0-ring material.

As discussed above, failure of the 0-ting can result in failure of the valve to perform its intended containment isolation function.

One of the 0-rings failed during the 1989 - 1990 Unit 2 operating cycle.

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

Pursuant' to the provisions of 10 CFR 2.201, you are required to-submit to this office within: thirty days of the date of this Notice a written statement or t'

1 explanation in reply, including for each violation: (1) the corrective actions i

that have been taken and the results achieved; (2) the corrective actions that will be taken to avoid further violations; and (3) the date when full compliance will be achieved.. Consideration may be given to extending your response time for good cause shown.

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b IS hb k Cw ~ ' hor Dated-H. J. Miller, Director Division of Reactor Safety s

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