ML20045B499
| ML20045B499 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/10/1993 |
| From: | Hausman G, Jablonski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045B495 | List: |
| References | |
| 50-254-93-09, 50-254-93-9, 50-265-93-09, 50-265-93-9, NUDOCS 9306180014 | |
| Download: ML20045B499 (9) | |
See also: IR 05000254/1993009
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U. S. NUCLEAR REGULATORY COMMISSION
REGION H I
Report Nos. 50-254/265-93009(DRS)
Docket Hos. 50-254; 50-265
Licensee: Commonwealth Edison Company
Executive Towers West III
1400 Opus Place, Suite 300
Downers Grove, IL 60515
Facility Name: Quad Cities Nuclear Power Stction, Units 1 and 2
Inspection At: Quad Cities Site, Cordova, IL 61241
Inspection Conducted: February 24-26, April 19-23 and May 27, 1993
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Inspector:
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Approved By:
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F. A. Jablonski, Chief
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Maintenance and Outages Section
anspection Summary
Inspection on February 24-26. April 19-23. and May 27, 1993 (Report Nos.
50-254/265-93009(DRS))
Areas Inspected: Special inspection, assessment, and evaluation of fire
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protection activities reported by the licensee in licensee event report
(LER)92-032, " Administrative Requirements / Commitments For Fire Protection Not Met
Due To A Management Deficiency." Portions of NRC inspection procedure 92700 were
used during the inspection.
Results: Overall, certain activities in the area of fire protection were not
effectively managed in meeting the program's safety objectives.
The following
apparent violations were identified:
Unit 2 was operated more than 67 days with Unit 1 RHR service water system
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loop A (opposite unit / shared unit safe shutdown (SSD) component) inoperable
(Section 2.2).
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Procedures were not established to track opposite unit / shared unit SSD
components when equipment was taken out-of-service (Section 2.2).
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Corrective actions were not timely in: establishing controls to track
opposite unit / shared unit SSD components when equipment was taken
out-of-service (Section 2.3); and establishing a test program to
9306180014 930614
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periodically demonstrate component operability for certain'SSD components
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(Section 2.3).
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A test _ program was not established for certain SSD components (Section 2.4).
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Fire protection equipment was not tested in accordance with established
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procedures (Section 2.5).
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A " Critical Zone Fire Protection System" was not maintained; long standing
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NFPA code violations existed without effective management attention
(Section 2.6).
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1.0
Princioal Persons Contacted
Commonwealth Edison Company
R. Pleniewicz, Site Vice President
J. Burkhead, Quality Verification Superintendent
- + D. Craddick, Maintenance Superintendent
- + H. Hentschel, Operations Manager
- + D. Kanakares, Regulatory Assurance NRC Coordinator
J. Leider, Technical Superintendent
- + J. Masterlark, Fire Protection System Engineer
- + A. Misak, Regulatory Assurance Supervisor
- + H. Smith, Fire Marshal
J. Tietz, Executive Assistant
U. S. Nuclear Reaulato'ev Commission
F. Jablonski, Section Chief, Maintenance and Outages Section
+ D. Liao, Reactor Engineer
+ Denotes those present at the interim exit meeting on April 23, 1993.
- Denotes those present at the exit meeting on May 27, 1993.
Other persons were contacted as a matter of course during the inspection.
2.0
Introduction
The purpose of this inspection was to review and assess licensee activities
concerning licensee event report (LER)92-032, " Administrative
Requirements / Commitments For Fire Protection Not Met Due To A Management
Deficiency." The voluntary LER was submitted on January 7,1993.
The LER identified several problems with the fire protection (FP) program and safe
shutdown (SSD) equipment. However, the licensee's description of FP and SSD
program problems was not detailed, specific system / component requirements and
FP/SSD equipment affected (except for the rotor _ unstacking transformer) was not
specifically identified, neither corrective actions nor completion dates were
specific, previous events were not accurately ider.tified. As of May- 27, 1993, the
licensee had not verified operability of the affected SSD fire protection
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systems / components. The inspector identified the following problem areas:
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Technical Specifications (15) did not contain all TS related FP
requirements.
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SSD component LCOs' were exceeded without appropriate action statements
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being implemented.
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Action was not taken to correct deficiencies identified with controlling
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opposite unit / shared unit SSD systems and certain SSD components.
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A test program was not established for certain SSD components.
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The FP program procedure was not followed or correctly implemented,
Long standing FP code violations existed on turbine rotor unstacking
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transformers.
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2.1
Backaround
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As a result of reviewing LER 92-032, the inspector identified multiple examples
where FP equipment had not been included in the TS. There appeared to have been a
loss of control with the process for adding and removing FP requirements from TS.
On July 3,1980, the licensee made a proposed amendment to the NRC to include in
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the TS the systems identified below with a " * "; however, the systems were never
included in the TS.
It appeared that the other systems were never submitted to
the NRC for incorporatio,1 into TS. The following FP systems were installed in
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fire areas where SSD or safety related equipment was located, but were not
included in TS.
U1 & U2 Turbine Oil Tanks
Ul & U2 Hydrogen Seal Oil
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MG Set Water Curtain
VI & U2 Rotor Unstacking Transformers
Detection Instruments located in the, Control Room *,
A and B Diesel Fire Pumps, Auxiliary Electric Room',
Ul & U2 Cable Tunnel', VI & U2 Batt'ery Switchgear Room',
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U1 & U2 Battery Room", Ul & U2 480 V and 4kV Switchgear (TB 639'and
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647')* and other VI & U2 fire detection instruments
Ul & U2 RHR Service Water Vaults' and other wet pipe sprinkler systems
Various VI & U2 preaction sprinkler systems
Various VI & U2 deluge systems
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An apparent contributing factor to the cause of this problem was the confusion
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caused when the NRC issued Generic letter (GL) 86-10 and 88-12. The GLs allowed
the licensee to remove the FP requirements from TS after following the prescribed
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process including preparation of a submittal and receipt of approval from the NRC.
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On April 26, 1989, the NRC issued a letter acknowledging the licensee's August 16,
1988, proposed TS amendment to revise reporting requirements for fire suppression
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These "LCOs" are not identified in the TS.
The 7 and 67 day
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"LCOs" are identified in the FP Report (FPR), Paragraph 4.16.2.
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The FPR is required per 10 CFR 50.48, " Fire Protection" and TS , 6.2, " Procedures and Programs."
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systems.
The NRC stated that the requested amendment was no longer. necessary
since it would be superseded in its entirety by an upcoming TS amendment being
submitted in accordance with GLs 86-10 and 88-12; therefore, the NRC considered
the proposed amendment withdrawn.
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On August 29, September 30, and October 2,1991, the licensee issued proposed TS
amendments to remove the FP requirements from IS, but would incorporate the FP
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program and major commitments, including the fire hazards analysis, by reference
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into the Updated Final Safety Analysis Report. On May 13, 1993, the NRC issued
Amendment Numbers 141 and 136 (Units 1 and 2, respectively), which found the
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proposed amendments acceptable, provided the SSD makeup pump was added to TS
(proposed TS addition for SSD makeup pump was issued per licensee letter dated
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March 23, 1993).
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2.2
Safe Shutdown Component LCOs' Were Exceeded Without Acoropriate Action
Statements Beina Implemented
At the inspector's request, the licensee reviewed equipment history records and
identified multiple occurrences where opposite unit / shared unit SSD component
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7 day "LCOs"' were exceeded and oae 67 day "LC0"' was exceeded. The most
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significant ', stance was where the Unit 1 RHR service water system was taken
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out-of-service for 120 days from November 14 1990, to March 15, 1991, with Unit 2
at power.
This resulted in the 67 day "LC0"y being exceeded by 53 days and the
affected plant (Unit 2), which was required by the "LC0"' to be shutdown, remained
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operating. This condition is significant because in the event of a design basis
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fire on the affected plant (Unit 2), damage may have occurred to the affected
plant's SSD equipment to the extent that safe shutdown of Unit 2's reactor would
not have been achieved or maintained.
Operation of Unit 2 with Unit 1 RHR service
water system loop A (opposite unit / shared unit SSD component) inoperable for more
than 67 days is an apparent violation of 10CFR50, Appendix R, Section III,
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Subsection G, " Fire Protection of Safe Shutdown Capability," Paragraph 3.
(254/265-93009-01(DRS))
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The inspector determined that no written procedures were established to track
opposite unit / shared unit SSD components when equipment was taken out-of-service.
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As a result, the licensee was unaware that a potentially significant Appendix R
safe shutdown component "LC0"' was exceeded.
This condition was not discovered
until the inspector requested that the situation be reviewed by the licensee. Not
having procedures established to track opposite unit / shared unit SSD components
when equipment is taken out-of-service is an examplc of an apparent violation of
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TS 6.2, " Procedures and Programs," Paragraph A.7. (254/265-93009-02A(DRS))
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These "LCOs" are not identified in the TS.
The 7 and 67
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"LCOs"
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identified
in the FP Report
(FPR),
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Paragraph 4.16.2.
The FPR is required per 10 CFR 50.48,
" Fire Protection" and TS 6. 2,
" Procedures and Programs. "
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2.3
Action Was Not Taken To Correct Deficiencies Identified With Controllina
Opposite Unit / Shared Unit SSD Systems And Components
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The licensee failed to take timely action to correct deficiencies with controlling
opposite unit / shared unit SSD components and testing certain 10 CFR S0,
Appendix R, SSD components even though there had been prior notice.
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In a licensee letter dated August 29, 1986, to all Station Managers
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(B. Rybak Letter), Attachment 2, Paragraph A, stated that several of Quad
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Cities' SSD paths utilize the unaffected unit's auxiliary power train and
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RHR service water pumps to safely shutdown the affected operating unit. For
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example, Quad Cities Unit 1 equipment is used in the shutdown of Quad Cities
Unit 2 and vice versa. The letter stated that controls should be imposed on
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opposite unit / shared unit SSD components not covered by technical
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specifications, such as, Divisions 1 & II AC auxiliary power systems, and
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RHR service water pumps. The licensee took no action in response to this
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apparent problem.
lack of controls for opposite unit / shared unit SSD components, was again
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identified in the licensee fire protection assessment report dated
December 7, 1989. A Category 1 item was issued with a written response due
by January 8, 1990. The licensee attempted to address the item by
committing to complete an analysis by June 1,1990;
however, this did not
address the assessment report item, which was to implement administrative
controls on opposite unit / shared unit SSD equipment.
The licensee did not
meet the due date for this assessment report item. The followup fire
protection assessment report dated May 29, 1990, expressed concern in
raeeting the due date due to strained manpower resources. The inspector also
noted that during the past five years there were five FP system engineer
turnovers. The " Fire Protection Action Plan" developed on December 22,
1992, identified a scheduled " target date" of August 30, 1993, to implement
approved procedures. The licensee currently does not have procedures to
control opposite unit / shared unit SSD equipment. At the inspector's
prompting, by March 1993, the licensee developed an interim method (SSD
Equipment Outage Record Form) to track opposite unit / shared unit SSD
equipment during the Unit 2 outage (started March 6,1993 and ended May 27,
1993).
The licensee f ailed to establish written procedures and implement periodic
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testing of SSD components in response to an issue that was identified by the
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B. Rybak Letter dated August 29, 1986, and again during the fire protection
assessment report, which was completed December 7,1989. A Category 1 item
was issued during the audit that required a written response by Jar.uary 8,
1990, when the licensee stated that procedures would be written to test the
SSD components by June 1,1990.
The licensee did not complete the
procedures. On May 29, 1990, the followup fire protection assessrent report
included a concern about meeting the due date because manpower resources
were not sufficient. To date, the licensee does not have procedures in
place to test the SSD components and as a result, has not inspected or
tested the SSD components. As of May 27, 1993, the licensee had r.ct
verified operability of the affected SSD fire protection systems /ccmponents.
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The " Fire Protection Action Plan" developed on December 22, 1992, identifies
a scheduled " target date" of December,30,1993, to implement these written
procedures.
Failure to take timely corrective action in these three instances is an apparent.
violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action."
(254/265-93009-03(DRS))
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2.4
A Test Proaram Was Not Established For Certain SSD Components
Test procedures had not been established to periodically demonstrate operability
of certain 10 CFR 50, Appendix R, SSD components. SSD components required to
perform various manual actions needed for reactor shutdown were identified in a
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licensee letter dated August 29, 1986, to all Station Managers (B. Rybak Letter).
Attachment 2, Paragraphs B and C, identified specific local transfer switches,
alternate feed breakers, local control switches,' isolation switches, crosstie
manual valves and other SSD components. As of May 27, 1993, the licensee had not
verified operability of the affected SSD fire protection systems / components.
Failure to establish a test program to assure that all testing required to
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demonstrate that structures, systems, and components will perform
satisfactorily in service is an apparent violation of 10 CFR 50, Appendix B,
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Criterion XI, " Test Control." (254/265-93009-04(DRS))
2.5
Fire Protection Prooram Procedure Not Followed Or Correctly Imolemented
The following three requirements of procedure QAP 1170-19, " Administrative
Requirements for Fire Protection," Revision 2, were not being followed or
correctly implemented for the systems identified in the examples below:
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Fire protection system surveillance actions were not followed.
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For all non-TS fire protection systems, the fire protection systems were not
declared inoperable under the correct circumstances; the licensee did not
understand when the fire protection systems were required to be operable.
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The reporting requirements described in the procedure were _not implemented
for all non-TS fire protection systems.
As a result, the fire detection instruments in the following systems were not
tested at least once per 6 months to demonstrate operability.
,:
345 KV Relay House
UI & U2 Main Transformer
UI & U2 Aux Transformer
Ul & U2 Reserve Aux Transformer
UI & U2 Turbine Oil Tanks
UI & U2 Turbine Bearings
VI & U2 Hydrogen Seal Oil
UI & U2 Exciter Housing
MG Set Water Curtain
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Also, as a result, the following test / inspection requirements were not completed
at least once per operating cycle on the U1,& U2 rotor unstacking transformer and
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the MG set water curtain.
Functionally test the system including simulated automatic actuation and
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verify that any automatic valves in the flow path move to the correct
position.
Inspect the sprinkler system piping to verify its integrity.
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Inspect each sprinkler head or nozzle to verify the discharge spray pattern
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is not blocked or obstructed.
Failure to establish, implement, and maintain written procedures for the fire
protection program is an example of an apparent violation of TS 6.2, " Procedures
and Programs," Paragraph A.7. (254/265-93009-02B(DRS))
2.6
Fire Protection Code Violations On Turbine Rotor Unstackina Transformers
The licensee failed to maintain a " Critical Zone Fire Protection System"* by
allowing long standing NFPA code violations to exist without effective management
action. The oil filled 13.8 kV transformers are located on the turbine building
main floor. Each transformer contains approximately 450 gallons of oil. The
transformers were temporarily installed in 1983, to supply power to heaters used
for turbine rotor unstacking work. On or about November 22, 1988, the licensee
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decided to leave the system permanently in-place. The licensee performed an
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evaluation on April 4,1989, to determine if the fire protection system
installation was adequate. The evaluation report included several NFPA code
violations, some of which were significant. On November 20, 1991, the licensee
submitted a modification request to correct the known deficiencies or remove the
system from service. The modification was reviewed by the station's pre-station
modification review committee (SMRC) and received a priority ranking too low for a
modification to be initiated, which effectively put the modification on hold.
To
date no management actions have been taken to resolve these problems, except for
grouting a fire seal, which was completed on March 29, 1993.
Failure to maintain
a fire protection system is an example of an apparent violation of TS 6.2,
" Procedures and Programs," Paragraph A.7. (254/265-93009-02C(DRS))
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A " Critical Zone Fire Protection System" is a fire protection
system that is located within a critical zone that must remain
operational to protect the SSD cabling or equipment located within
that critical zone.
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3.0
Conclusion
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Based on the review of associated documentat'i'on, interviews with personnel, and
inspection observations, the inspector concluded that an apparent breakdown of
administrative controls existed within the licensee activities associated with FP
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program implementation as evidenced by the following:
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Management's attention to fire protection problems was not proactive. Known
problems were allowed to persist as identified in Section 2.3, 2.4 and 2.6.~.
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As a result, a potentially significant FP "LC0" was exceeded without
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management's awareness as identified in Section 2.2.
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Resolution of identified problems were neither timely nor comprehensive as
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identified in Sections 2.3.
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Prioritization of known problems was inadequate, as identified in Sections
2.3, 2.4 and 2.6.
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An apparent contributing factor, which affected continuity of following up on FP
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issues, was the frequent turnover of fire protection system engineer as identified
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in Section 2.3 and strained manpower resources as identified in the licensee's FP
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assessment audits dated December 7, 1989, and May 29, 1990.
4.0
Exit Meetina
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The inspectors met with licensee's representatives (denoted in Paragraph 1) during
the inspection period, on April 23 and at the conclusion of the inspection on
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May 27, 1993.
The inspectors summarized the scope and results of the inspection
findings. The inspectors discussed the likely content of- the inspection report
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with regard to documents or processes reviewed by the inspectors. The licensee
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acknowledged the information and did not indicate that any of the information
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disclosed during the inspection could be considered proprietary in nature.
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