ML20056H137
| ML20056H137 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/30/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9309080273 | |
| Download: ML20056H137 (8) | |
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O7 Commenw;alth Edison O
1400 Opus Place Downers Grove, tilinois 60515 August 30, 1993 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Quad Cities Nuclear Power Station Unit 2 Response to Notice of Violation Inspection Report Nos. 50-265/93012 NRC Docket Numbers 50-265
Reference:
J.B.
Martin letter to M.J. Wallace dated July 30, 1993, transmitting Notice of Violation and Proposed Imposition of Civil Penalties - $100,000 Enclosed is Commonwealth Edison Company's (CECO) response to the
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Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report.
The NOV cited three violations; Violation I.A for the operation of Unit 2 between August 15, 1972, and March 6, 1993, with the Unit 1/2 diesel generator inoperable contrary to Technical Specifications; Violation I.B for the operation of Unit 2 between February 16 and March 6, 1993 with the Unit 2 diesel generator inoperable contrary to Technical Specifications; and Violation II for failure to submit a Licensee Event Report within 30 days of discovery of the cooling water pump bearing problem.
Violation I.A and I.B are Severity Level III violations requiring a written response, and civil penalties of $75,000 and $25,000' respectively, a total of $100,000.
Violation II is a severity Level IV violation requiring a written response.
CECO's response and payment of the civil penalties are provided in the attachment.
If your staff has any questions or comments concerning this letter, please refer them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287.
Resp
- tfully, J w_'- _,
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Dennis Farrar, Manager Regulatory Services MJ/gp Attachment cc:
J. Martin, NRC Regional Administrator - RIII R. Assa, Project Manager - NRR 0g S. DuPont, Senior Resident Inspector p8 k:/rpa/en! con / quad /dgre/1 Ihd4, k n
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l ATTACHMENT j
RESPONSE TO NOTICE OF VIOLATION i
NRC INSPECTION REPORT 50-265/93012 VIOLATION: (265/93012-I.A) l Technical Specification 3.9.A.1 requires that the reactor shall not be made critical unless the Unit 1/2 diesel generator is operable.
Technical Specification 3.9.E.1 requires, in part, that whenever the reactor is in Startup/ Hot Standby or Run mode and the shared diesel generator is inoperable, continued reactor operation is permissible only during the succeeding 7 days provided that j
i certain requirements are met.
Technical Specification 1.0-2.M defines a system, subsystem, train, component, or device as operable when it is capable of performing its specified function (s), assuming that all necessary attendant cooling water equipment, among other things, that is required f or the syste a, subsystem, train, component, or device l
to perform its function (s) are capable of performing its related support function.
Contrary to the above, on numerous occasions from August 15, 1972 until March 6, 1993, the Unit 1/2 diesel generator was inoperable l
in relation to Unit 2, and Unit 2 was made critical, or was in Startup/ Hot Standby or Run modes for periods of time greater than 7 days.
Specifically, the Unit 1/2 diesel generator cooling water pump, required for the Unit 1/2 diesel generator to perforr its intended function, was incapable of starting during a Unit 2 loss of cooling accident coincident with a total loss of offsite power.
REASONS FOR THE VIOLATION:
Commonwealth Edison acknowledges the violation.
The reason for the violation is the result of an original plant design that i
caused the Unit 1/2 Diesel Generator Cooling Water Pump (DGCWP) to be inoperable during accident conditions.
I A design deficiency in the Unit 1/2 DGCWP logic circuit would result in a lock-out of the pump during a te :a1 loss of offsite power concurrent with a Unit 2 LOCA.
l Furthermore, CECO acknowledges the missed opportunities to identify the violation.
Those prior opportunities include the review of Information Notice 88-75, and the 1992 post-i modification operability tests for the degraded voltage modifications.
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ATIACEMENT RESPONSE TO NCTTICE OF VIOIATION NRC INSPECTION REPORT I
50-265/93012 CORRECTIVE STEPS TAKEN AND PEULTS ANTWED:
Modification (M04-93-003A) was implemented to add undervoltage contact in the bus 28 close logic.
This undervoltage contact l
clears the close signal preventing breaker lock-up.
As a further enhancement, a modification will be installed to move a bus 18 undervoltage contact to a corrmon point where it i
will clear the closed signal independent of the position of the power select switch.
This modification will be installed during the next Unit 1 refueling outage Q1R13 which is scheduled for the spring of 1994.
Until the tradification can be completed a caution card will remain on the power select switch and cautions have been added to procedures identifying limitations with the power select switch.
CORRECI'IVE STEPS TAKEN 'IO AVOID FURTHER VIOIATIONS:
i Quad Cities reevaluated the applicability of Information Notice 88-75 and Supplement 1 for 480 volt and 4kV breakers (for Units 1 l
and 2).
No additional problems were identified, i
Quad Cities revised QCAP 2300-8, " Station Operating Experience Review and Response," to include guidance on the review of electrical distribution issues.
The guidance requires an evaluation of both electrical feeds for equipment having dual unit feeds if the scope of the review is limited to a single unit.
Quad Cities has incorporated GCo initiatives to improve CECO's process for contract oversight and review of engineering analysis.
A sample of tradifications will be selected from the modifications installed between 1980 and the present to examine the threshold for requiring operability tests.
A final report will be issued by October 1, 1993.
i Quad Cities Operating Surveillances, QOS 6500-1 and OOS 6500-4 I
will be revised to ensure that testing bounds a dual unit LOOP event.
These surveillances, performed during refuel outages, provide functional testing of 4KV bus 13-1(23-1) undervoltage logic.
The revision will be completed prior to the next refueling outage.
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ATTACHMEtfr RESPatiSE TO NOTICE OF VIOIATION NRC INSPECTION REPORT 50-265/93012 Quad Cities Engineering performed a design review of equipment i
required during accident conditions to ensure that a loss of off site power to both units would not prevent operation of equipment during accident operations. The review included the control circuits for the following equipment; 1/2 diesel generator output circuit breaker, bus undervoltage relays for 13-1, 23-1, 18, and 28, 1/2 diesel generator auxiliaries, and the equipment fed from l
busses 13-1, 23-1, 18, and 28. This review concluded that the equipment would perform its intended function.
I A follow up " Lessons Learned Green Border Notification" was issued to all CECO sites describing this event, its causes and corrective actions.
DAIILMBEtLHILL_CCEPLIANCE MAS ACHIEVED:
i Full compliance was achieved on April 27, 1993 when modification i
M04-93-003A was completed and authorized for operation.
This modification corrected the design deficiency on Bus 28 and restored operability to the 1/2 Emergency Diesel Generator to Unit 2.
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ATTACHMENT RESPONSE 'IO IUTICE OF VIOIATION NRC INSPECTION REPORT 50-265/93012 VIOIATION: (265/93012-I.B)
Technical Specification 3.9.A.1 reguires that the reactor shall not be made critical unless the Unit 1/2 diesel generator is operable.
Technical Specification 3.9.E.1 requires, in part, that whenever j
the reactor is in Startup/ Hot Standby or Run mode and the shared diesel generator is inoperable, continued reactor operation is permissible only during the succeeding 7 days provided that certain requirements are met.
Technical Specification 1.0-2.M defines a system, subsystem, train, component, or device as operable when it is cacable of performing its specified function (s), assuming that all necessary attendant cooling water equipment, among other things, that is required for the system, subsystem, train, component, or device l
to perform its function (s) are capable of performing its related l
support function.
1 Contrary to the above, from February 16 until March 6, 1993, the Unit 2 diesel generator was inoperable, and Unit 2 was made critical, or was in Startup/ Hot Standby or Run trodes for periods of time greater than 7 days.
Specifically, the Unit 2 diesel generator cooling water pump, required for the Unit 2 diesel generator to perform its function, was incapable of performing its related support function due to an indeterminate oil level in the pump bearing housing.
PEASONS FOR THE VIOIATION:
l Cotrmonwealth Edison acknowledges the violation.
The Unit 2 DGGiP bearing degradation was due to inadequate lubrication which was a result of the incorrect assembly of the oiler piping during pump maintenance in January 1992.
Tne oiler was incorrectly assemM ed due to inadequate training on the maintenance and surveillance of oilers.
l Due to inadequate training, scme mechanics were unaware of the l
proper way to assemble this type of oiler.
Additionally, some operators were unaware of how to properly determine oil level with this type of oiler.
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ATTACHMENT RESPONSE 'IO NOTICE OF VIOLATION NRC INSPECTION REPORT l
50-265/93012 i
CORRECTIVE STEPS TAKEN AND P E ULTS ACHIEVED:
I On April 2, 1993 the Unit 2 DGCNP was disassembled.
The bearing retainer ring, which provides spacing between the ball bearings were intact, but the maring and pump shaft had apparent heat damage.
The balls were coated with a heavy grease-like film.
A new DG09 was installed and the operability surveillance completed on April 10, 1993.
CORRECTIVE STEPS TAKEN 'IO AVOID Furrwxx VIOLATIONS:
Quad Cities Technical Staff perfcrmed walkdowns on safety and t
nonsafety related equipment sightglasses and oilers in the plant t
to ensure proper installation.
Quad Cities Operations Department held discussions on how to f
detennine proper oil level during operator rounds.
The Operator who perfonned the surveillance on February 10, 1993 was counselled by management on the proper technique for draining and refilling the oil on this type of oiler.
To address the inadequate training on oiler positioning, a i
detailed training session was conducted with maintenance personnel using the actual DGCNP hardware that was improperly l
positioned as a mockup and training guide.
A matrix of the different styles of oilers and sightglasses was develo:ed from joint Operations and Maintenance plant walkdowns.
From the matrix, an action plan was developed to contro] lesson plan revisions, enhance training and provide marking of all safety related sightglasses.
j Corporate groups and On-Site Quality Verification performed a self assessment to examine craft capability, work package detail and other maintenance practices.
Quad Cities Maintenance is currently reviewing the recottmendations for applicability.
The applicable reconmendations will be used to develop and implement an action plan.
i DATE wmW Furl. COMPT TANCE MAS ACHTFVED:
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Full compliance was achieved on April 10, 1993 when a new diesel generator cooling water pump was installed and successfully completed an operability surveillance.
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ATIACHMEtfr RESPONSE 'IO NCffICE OF VIOIATICN NRC INSPECTION REPORT 50-265/93012 I
VIOIATION: (265/93012-II) 10 CFR 50.73 (a) (2) (i) (B) requires, in part, that the licensee submit a Licensee Event Reoort within 30 days of discovery of any I
operation or condition pro:1ibited by the plant's Technical i
Specifications.
Contrary to the above, on March 29, 1993, the licensee discovered a condition prohibited by plant Technical Specifications, but did not submit a Licensee Event Reoort within 30 days.
Specifically, j
the licensee discovered that tae oilers on the Unit 2 diesel generator were not placed at a sufficient height to lubricate the pump bearings, and upon disassembly, that the bearings were severely damaged.
However, the licensee did not identify the l
damaged cooling water pump bearings, which occurred durinc3 the course of the previous reactor operation cycle, as a condition prohibited by the plant's Technical Specifications.
REASONS FOR THE VIOIATION:
l Ceco acknowledges the violation.
The Unit 2 vessel core was unloaded on March 15, 1993 and the diesel generator is not required to be operable in the defueled condition.
On March 29, 1993, an operator questioned the height of the oiler on the Unit 2 DGCWP during operator rounds.
Although several actions were taken including walkdowns, and initiating a Problem Identification Form, no LER was written. ' CECO believes that an
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LER was not written because the Station did not acknowledge that the pump was inoperable because the diesel generator had l
successfully completed its previous operability surveillances and l
had been taken out of service for scheduled maintenance on March 25, 1993.
The planned replacement of the DGCNP was implemented l
and installation and operability surveillance was completed by l
l April 10, 1993.
l CORREunVE STEPS TAKEN AND RESULTS ANTEVED:
l CECO submitted a Licensee Event Report on June 30, 1993 describing the event.
CORRECTIVE STEPS TAKEN TO AVOID run-M VIOIATIONS:
A " Lessons Learned Green Border Notification" was issued and distributed to appropriate departments.
This lessons learned document included discussion about the failure to report the Unit 2 cooling water pump bearing failure.
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ATTACHMENT l
RESPONSE TO N0 RICE OF VIOIATION i
NRC INSPECTION REPORT 50-265/93012 DATE.MWiN FULL OCHPLIANCE 1GS ACHIEVED:
l Full compliance was achieved on June 30, 1993 when a Licensee l
Event Report was suhnitted to the Nuclear Regulatory Comission.
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