ML20045H243
| ML20045H243 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/12/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307200006 | |
| Download: ML20045H243 (4) | |
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1400 Opus Place Downers Grove, Illinois 60515 July 12,1993 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 In spection Report Numbers 50-254/93011; 50-265/93011 NRC Docket Numbers 50-254 and 50-265
Reference:
Brent Clayton letter to L. O. DelGeorge dated June 9,1993 transmitting NRC Inspection Report 50-254/93011; 50-265/93011 Enclosed is Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report.
The NOV cited the failure to perform a temporary alteration for installation of pipe plugs in place of floor drain check valves prior to removal of the floor drain check valves. As a result, the affected ECCS components were made inoperable due to loss of flood protection. 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,
--- AA-uw D. L. Farrar Nuclear Regulatory Services Manager Attachment i
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J. Martin, Regional Administrator, RIII C. Patel, Project manager, NRR-T. Taylor, Senior Resident Inspector, Quad Cities 150086
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1 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93011; 50-265/93011 VIOIATION:
10 CFR 50, Appendix B, Criteria V states, in part, that activities affecting quality shall be prescribed by documented instruction of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions.
Contrary to the above, on March 31,1993, during installation of Emergency Core Cooling System (ECCS) room drain line strainers, a temporary alteration for installation of pipe plugs in place of floor drain check valves was not performed prior to removal of the drain line check valves. As a result, the affected ECCS components were made inoperable due to loss of flood protection.
REASON FOR VIOLATION:
Commonwealth Edison agrees with the violation. The investigation revealed that a temporary alteration, requiring installation of pipe plugs prior to commencement of maintenance on the check valves' lines, was not in place.
A revision was made to work package QO3829 to allow the floor drain pligs to be installed under the temporary alteration (temp alt) program. An appro, ad temp alt sheet and a revision sheet were added to the work package. The revision sheet stated, "This i
revision incorporated a temp alt to allow plugs to be put in and removed on lines going to the sump." However, no step was added to the recommended work instruction sequence of steps to install the temp alt before removal of the drain line isolation valves. The work analyst did not use a full traveller which would contain sequenced steps, prerequisites and sign-offs due to the work requests classification (non-safety related, non-regulatory related, non reliability related)
Operations and Maintenance did not confirm the installation of the temporary alteration.
Both departments assumed that the temporary alteration was installed.
With the check valves removed, the temporary plugs were required to fulfill the safety function of the check valves. The check valves had been removed at about 9:00 a.m. The plugs were installed at 3:00 p.m.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93011; 50-265/93011 J
COINtECTIVE ACTIONS TAKEN AND HESULTS ACHIEVED:
The immediate corrective action was to install the floor drain plugs to return the systems in the basement rooms to an operable status. Work was stopped on this work package until the package was revised to provide work steps of assuring the temporary alteration was installed. The work packages were then successfully completed.
Work Analysts were counseled in preparing work requests. They have the ability per QAP 1500-14, " Preparation and Control of General Work Requests" to enhance the level of detail in work instructions by use of a traveller regardless of the work request's classification ifin their opinion the work is sufIiciently complicated or if the work needs special coordination.
CORItECTIVE STEPS THAT WILL HE TAKEN TO AVOID FURTHER VIOLATIONS:
The investigation of this event determined that a number of problems contributed to the failure to ensure the proper installation of the floor drain plugs. The following corrective actions will be taken-A method will be developed to positively control temporary alterations used in n.
work package. This control will include a signature step to assure the completion of the temporary alteration installation. This action will be completed by September 15,1993.
b.
The Shift Engineers have been instructed to sign the " Shift Authorization to Start Work" only immediately prior to the actual work commencing in the field. This will allow for a review of the work package by the shift individuals who will be impacted by the work and allow for the shift engineer to assess the current conditions just prior to work initiation, A review has been performed of QAP 1500-T4, " Equipment, Components, and c.
Systems Exempt from the Reliability Related Program." This review yielded the recommendation that several systems be removed from the exempt list, thereby placing them in the Reliability Related Program. These procedure changes are in progress and will be completed by July 30,1993.
d.
The Temporary Alteration Approval Sheet, QAP 300-S3, will be enhanced and improved from a human factors standpoint so that the status of a temporary alteration is readily apparent. This improvement will be completed by September
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as RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/93011; 50-265/93011 After the completion of human factor improvements to the temporary alteration e.
process, training will be provided to all Maintenance foremen, work analysts, and Operating department licensed individuals on the temporary alteration process and the associated paperwork. This training will be completed by December 31,1993, for Operating Department and October 15,1993, fbr Maintenance Department.
f.
Instructions for the work request classification of" Technical Specification Yes/No" will be changed to clarify that work requests whose work could impact technical -
specification equipment should be marked "Yes." Currently the work request is classified as "Yes" only if an LCO entry is planned in order to do the work. This change will help in the determination of the level of detail needed in the work instructions. This revision will be completed by July 30,1993.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED:
Full compliance was achieved on March 31,1993, with performance of the temporary installation of the floor drain plugs.
NON SAFETY WOItK ACTIVITIES AFFECTING SAFETY RELATED SYSTEM OPEllATION:
Corrective Actions "a, b, d, e, and f" above apply to both non-safety and safety related equipment and work activities. Corrective Action "c" above applies to non-safety related equipment as safety related/ complex work packages already are required to have detailed work instructions. A review of non-safety related equipment which may affect safety related equipment has been completed. CECO believes that all non-safety related equipment which may affect safety related equipment has been added. to the reliability related program.
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