ML20044G127
| ML20044G127 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/18/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306020059 | |
| Download: ML20044G127 (5) | |
Text
C:mm:nwrith Edison
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j 1400 Opus Place
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J Downers Grove, Illinois 60515 Q,/
May 18,1993 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-254/93008; 50-265/93004 NRC Docket Numbers 50-254 and 50-265
Reference:
Brent Clayton letter to L.O. DelGeorge dated April 21,1993, transmitting NRC Inspection Report 50-254/93008; 50-265/93008 Enclosed is Commonwealth Edison Company's response to Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited two violations: 1) concerning inadequate corrective actions to prevent control rod misposition errors, and 2) concerning the lack of a calibration procedure for a flow meter in the EDG system. CECO's response is provided in the attachment.
If there are any questions or comments concerning this letter, please refer them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287.
Respectfully,
<h
'[' D.L. Farrar
'2'70000 Nuclear Regulatory Services Manager cc:
A. B. Davis, Regional Administrator, RIII C. Patel, Project Manager, NRR T. Taylor, Senior Resident Inspector, Quad Cities C
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9306020059 930518 PDR ADOCK 05000254 G
.o RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93008; 50-265/93008 VIOLATION: 254(265)93008-01 10 CFR 50, Appendix B, criteria XVI requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to l
quality, the measure shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, on March 15, 1993, during post maintenance testing of control rod C-4, the wrong control rod was inserted. Corrective actions taken for three previous control rod mispositionings were not adequate to preclude.
l the fourth mispositioning error on March 15.
l This is a Severity Level IV violation (Supplement 1).
REASON FOR THE VIOLATION:
Commonwealth Edison Company acknowledges the violation which resulted from personnel error by the Nuclear Station Operator (NSO) during the testing of control rod C-4.
During timing adjustment, the NSO selected an edge control rod to bypass the Rod Block Monitor (RBM) to prevent constant spurious alarms and automatic resets.
When the adjustment had been nede and the control rod was to be timed, the NSO failed to self check that the correct control rod was i
selected.
The SCRE, overviewing the job, immediately noticed the wrong rod was being moved and alerted the NSO.
The NSO ctopped the rod movement and the control rod settled two notch positions (position 44) from its target position j
of 48.
l Regarding the most previous event, a level 3 investigation was initiated because of the repetitive nature of these events.
The investigation was expanded to include the latest event.
The first two events occurred on a reactor startup and occurred on the same shift by the same individual. After the first event startup was halted, the cperator involved was counselled to use self check in the selection of control rods.
When'the second event happened later in the same shift, appropriate disciplinary action was administered. These corrective actions taken were specific to the event and Ceco believed were appropriate. Subsequent to the fourth mispositioning error, Quad Cities Operations initiated comprehensive corrective actions which will preclude further recurrence.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
f The control rod involved in this event and the control rods in the previous events were immediately returned to their target positions in accordance with QCOA 300-4 "Mispositioned Control Rod."
Senior site management is. conducting detailed discussions regarding this event with Operations personnel.
Emphasis is being specifically placed on management's expectations regarding the use of the self check principle.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
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Procedure QCGP 4-1,
" Control Rod Movements and control Rod Sequencing" is-being enhanced as follows: A second verification is required anytime that control rods are being manipulated.
A Qualified Nuclear Engineer (ONE),.
Nuclear Station Operator (NSO) or a test director will be required to perform an independent verification of each control rod movement if the Rod Worth Minimizer (RWM) is disabled. Anytime a ONE is required to be in the Control Room he will provide an independent verification of every control rod RAWRCMO93(K* 1 C.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93008; 50-265/93008 f
movement. The procedure revision will be completed by June 25, 1993.
During the next two reactor startups, from commencement of rod movement until l
Generator Sychronization, the crew will be supplemented with a fifth NSO.
This will allow the crew to dedicate one NSO strictly for control rod movements and low power ascension. An evaluation will be performed on the j
effectiveness of the dedicated NSO and his impact on the crew make up after the next two reactor startups.
Classroom and Simulator trainina will be provided by June 25, 1993 for all licensed and nuclear engineering personnel on the new verification process and procedure revisions.
f The Rod Worth Miniminer (RWM) software will be enhanced to provide a Select
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Block and a Rod Exercise Block. These blocks will aid in preventing an out of i
sequence control rod from being moved during normal rod movement and allowing
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one notch control rod insertion during CRD exerci. ming.
RWM software enhancements will be completed by September 30, 1993.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
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Pull compliance will be achieved with the completion of Senior Management diccussion with Operations personnel.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93008; 50-265/93008 VIOLATION: 254(265)/93008-03 10 CFR 50, Appendix E, Criterion V states, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances.
Contrary to the above:
In February 1993, calibrations of the 1/2 diesel generator Barton flow meter were performed without instructions of a type appropriate to the circumstances.
This is a Severity Level IV violation (Supplement 1).
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REASON FOR VIOLATION:
commonwealth Edison agrees with the violation. The violation is based upon failure to perform calibrations of the 1/2 diesel generator cooling water pump flow indicator with instructions of a type appropriate to the circumstances.
On February 11, 1993 Surveillance QCOS 6600-8, Diesel Generator Cooling Water to Unit 2 Emergency Core Cooling System Check Valve (2-3999-139) was being t
performed. The surveillance was unsuccessful because the required. flows could not be met.
The Instrument Maintenance Department was contacted to. calibrate the flow indicator.
The assigned IMs performed the calibrations based on their experience; a calibration procedure was not available. Upon closer examination of the calibration method, it was determined that the methods used for the wet and
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dry calibrations were applied inconsistently. Once the calibration had been performed utilizing only one of the methods (in this case wet cal), results
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were obtained that satisfied the surveillance requirements.
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CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
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t A QCIP 100 series procedure will be written to assure continued use of i
appropriate techniques when performing in-plant calibrations. The appropriate method of calibration and reference steps which delineate the necessary actions required to perform satisfactory wet or dry calibrations will be included in the procedure. The procedure changes will contain. appropriate
-notes / precautions concerning instrument line air / water removal and water bottle positioning.
The procedure changes will be implemented by June, 15 1993.
t The Master Instrument Mechanic will discuss this event with the IMs by June 15, 1993 during a weekly tailgate meeting.
RANNRCNRWVM.
I RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93008s 50-265/93006 CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
To improve IM
- E' technician understanding of the optional calibration and appropriate techniques, training requests have been submitted to site training for inclusion of specific training on the use of water bottles (wet cal) or air (dry cal) when calibrating differential pressure (flow) indicators.
Addition of this initial IM training to the site specific program will be completed by July 1993.
A review of techniques associated with the proper performance of wet and dry calibrations will be provided to IM technicians by July 31, 1993.
The review will consist.of the appropriate actions, necessary precautions and thought process to be taken during wet / dry calibrations to assure that the calibration is performed satisfactorily.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by June 15, 1993, with procedure implementation.
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