ML20058E732
| ML20058E732 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/29/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312070148 | |
| Download: ML20058E732 (10) | |
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Commonws lth Ediron f
G5 1400 Opus Place Downers Grove, libnois 60515 November 29,1993 1
L Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i
1 Attn: Document Control Desk
Subject:
Quad Cities Power Station Units 1 and 2; i
NRC Docket Number 50-254 and 50-265; l
NRC Inspection Report Numbers 50-254(265)/93025
Reference:
Edward G. Greenman letter to M. J. Wallace dated October 26,1993, transmitting Notice of Violation.
j Inspection Report 50-254/93025; 50-265/93025 j
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. Enclosed is Commonwealth Edison's response to the Notice of Violation (NOV) transmitted with the referenced letter. The NOV cited four Severity Level IV violations; one violation with two examples pertaining to inadequate procedures, one violation concerning inadequate corrective actions to prevent recurrences of personnel errors, j
one violation regarding a missed 50.72 report when a plant condition was found l
outside of the design basis, and one violation concerning inadequate test control of core spray valves.
l The violation regarding a missed 50.72 report when a plant condition was found
.l outside of the design basis, will be answered separately from this response as dialog
'l between NRC Region lli and Commonwealth Edison continues on this subject. This response will be submitted on December 3,1993.
i The referenced letter requested that we specifically address planned corrective actions regarding management oversight to improve task performance. These corrective actions are being addressed in our response to the Diagnostic Evaluation j
- Team (DET) Report.
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r If there are any questions or comments concerning this letter, please refer them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287 l
Respect j
M.
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I L. Farrar, Man er s/
Nuclear Regulatory Services Attachment i
cc: J. Martin, Regional Administrator, Rlli C. Patel, Project Manager NRR T. Taylor, Senior Resident inspector, Quad Cities
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ATTACHMENT NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 VIOLATION: 254(265)/93025-01a Quad Cities Technical Specification 6.2.A.1 states.the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2 dated February 1978, shall be established, implemented, and maintained. Regulatory Guide 1.33 Appendix A.I.c included administrative procedures, general plant operating procedures, and procedures for startup. operation, and shutdown of safety related systems.
Contrary to the above, on August 21,1993, during operability surveillances on both unit high pressure coolant injection (HPCI) systems, the surveillance procedure was inadequate in that it did not contain appropriate information to direct valve manipulations which rendered both unit HPCI systems inoperable.
REASONS FOR THE VIOLATION:
CECO acknowledges the violation. The HPCI System Engineer directed the Operating Department Equipment Attendants (EA's) to drain the HPCI exhaust drain
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pots prior to a planned HPCI surveillance on each unit to insure water had not built up in the HPCI drain systems. The Unit 1 HPCI interim procedure did not address
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opening the drain valve. The Unit 2 HPCI interim procedure had a step for the draining but it did not include the valve number. After the drain check was complete, the System Engineer pointed out and directed that the EA close two valves on the J
drain systems. The System Engineer believed that these two valves were in series with the drain opening in the drain pot and that the valves merely isolated the opening.
The System Engineer believed this because he had in mind the valve configuration for i
the HPCI steam supply drain pot. When the EA closed these two valves, one valve was actually isolating the lower sensor line to the HPCI exhaust drain pot level switch.
The HPCI surveillances were completed normally. The System Engineer then directed that the drain pots be checked and drained periodically for eight hours to insure the drain pots remained empty. An EA, on the later shift, performing this drain check, discovered the lower sensor line isolation valve closed, in addition to the proper drain opening isolation valve being closed. The valve position was immediately corrected after checking with Operating Supervision.
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ATTACHMENT NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Upon discovery, the valve lineups were returned to their correct positions. The Station and General Electric completed an in depth review of HPCI testing methods. The HPCI test procedures were then re-written and new permanent surveillance procedures were implemented. These new procedures address all manipulations needed for the surveillances.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
To insure better quality Interim Procedures, administrative procedures QCAP 1100-4, Procedure Revision, Review and Approval, and OCAP 1100-5, Processing i
interim Procedures will be revised to allow only one Interim Procedure to a single existing procedure, to insure notification sheets are completed for each procedure affected by an interim Procedure, and to establish requirements for use of applicable portions of the writer's guide when writing an interim procedure. These changes will be completed by December 31,1993.
l OCAP 230-5, independent Verification, will be reviewed to include an independent verification of manual valve position. This review and recommendation will be completed by April 15,1994.
A formal Operating Department Policy has been issued to clearly define how activity direction and recommendations by non-operating personnel (including vendors) are to l
be submitted, controlled, and conveyed to Operations Personnel for performance of j
plant evolutions and activities.
j The System Engineer Supervisor will define written expectations for the method in which System Engineers provide direction and evaluation data to other organizations (Operations, Maintenance, Management). This expectation document will be issued and implemented by April 30,1994.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED:
I Full compliance was achieved on September 18,1993, when the new HPCI surveillance procedures went into effect.
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ATTACHMENT NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 4
VIOLAllON: 254(265)/93025-01b Nuclear Operating Directive NOD-TS.20, " Emergency Diesel Generator Reliability Program" requires maintenance to be designed for both preventive and corrective actions based upon operating history and past maintenance activities, vendor recommendations, spare parts considerations, and the results of surveillance testing.
Contrary to the above, the diesel generator preventive maintenance (PM) program failed to include several vendor recommended PM activities. Examples included vendor recommendations for replacement of lower liner seals and cylinder head to liner water grommets.
This is a Severity Level IV Violation (Supplement 1).
REASONS FOR THE VIOLATION; Commonwealth Edison acknowledges the violation. Quad Cities PM program failed to
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include several of the vendor recommended PM activities for the Emergency Diesel Generator (EDG) which were found in the Electro-Motive Division (EMD) Maintenance Instruction (MI) 1742.
CQBRECTIVE STEPS TAKEN AND RESULTS ACHIEVED j
A review of MI 1742 has been performed by the System Engineer and Maintenance to identify recommended activities which were not being performed. This review was completed in mid 1992. Many of the activities, which were not included in Quad Cities PM Program previously for the EDG were added at that time.
i Activities, which were not added from the 1992 review, were addressed by the EMD EDG Owners Group. The EMD EDG Owners Group consists of twenty utility members and EMD representation. This Group has developed a maintenance instruction for EDGs based upon the type of service which is seen in the Nuclear Industry. This document was issued to the station in July of 1993. Quad Cities will be using this document as the bases of its PM Program for the EDG instead of MI 1742.
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ATTACHMENT NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 l
C_ORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Some of the activities to be completed during the R13 refuel outages include, replacement of the lower liner seals and replacement of cylinder head gaskets and cylinder head to liner water grommets for the respective unit EDG.
C_ORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
All EMD EDG Owners Group maintenance instruction recommendations, which are applicable, will be incorporated into the PM program by December 31,1993.
Implementation of these recommendations are currently scheduled fc. completion by December 31,1994.
To ensure vendor recommendations on other station equipment is considered,-
Procedure OCAP 450-03 " Vendor Equipment Technical Information Review" will be j
revised. This revision will require the System Engineer to perform a review of vendor manual recommendations that will be considered for incorporation into the station PM program. This procedure will be revised and approved by April 1,1994. Review of i
Safety Related Manuals are to be completed by June 1997 and Nonsafety Related Manuals are to_be completed by June 1999.
DATE WHEN Ft)LL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved, by December 31,1993, when the PM program will be I
revised to include the EMD EDG Owners Group recommendations.
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ATTACHMENT NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 VIOLATION; 254(265)/93025-02 10 CFR 50, Appendix B, Criteria XVI requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, corrective actions taken to ensure performance of a self-check i
during task performance, in response to a January 1991 vessel drain down event, were not adequate. Specific examples of a lack of self-check by personnel were as follow:
a.
On September 3,1993, a nuclear shift (station) operator started the lA residual heat removal (RHR) pump instead of RHR service water pump during a surveillance activity; 7
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On September 5,1993, an equipment attendant opened the wrong valve resulting in transferring water in reactor building drain tank to contaminated condensate storage tanks instead of the river discharge tank; and c.
On August 21,1993, during operability surveillances on both unit HPCI systems, the isolation valves to the high side sensing line of the drain pots were mispositioned rendering the systems inoperable.
This is a Severity Level IV violation (Supplement 1).
REASONS FOR THE VIOLATION:
i CECO acknowledges these violations, In two cases, personnel involved in the evolutions failed to ensure that the correct components were being operated prior to i
manipulation and in the third instance, appropriate documents were not checked prior to determining a post evolution valve lineup.
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t ATTACHMENT NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
In all three cases, immediate corrective actions were taken to restore the system configurations as required. Discussions have been held with each Operating crew to reemphasize the importance of establishing a habit of performing a proper self check j
prior to any equipment operation. To help establish the habit of self check, during the wee'K of September 5,1993, each shift engineer screened each activity, that was to be performed and made a conscious decision whether an extra person would accompany the individual performing the task as a reminder of self check. Disciplinary actions l
were administered to each individual involved in these events in order to emphasize the expectations of management and the accountability of the individuals to meet those expectations.
C_ORRE_QTIVE STEPS TAKEN TO AVO1D FURTHER VIOLATIONS:
Quad Cities Station will continue to stress the need for all personnel to perform self checking during the performance of activities and will continue to iloid personnel accountable for that performance. The self-check program established in 1991 is being enhanced to emphasize supervisor and manager reinforcement and suppcrt of self-checking. Training will emphasize when to self-check. Lessons learned from station operating experience to ensure a comprehensive and coordinated station program.
i DATE WHEN FULL, COMPLIANCE WAS ACHIEVED:
Full compliance was achieved on September 8,1993, when the discussions were held l
with each operating crew to reemphasize the importance of establishing a habit of j
. performing a proper self check prior to any equipment operation.
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ATTACHMENT NOTICE OF VIOLATION i
INSPECTION REPORT 50-254(265)/93025 y1OJ.ATION: 254(265)/93025-05 10 CFR 50, Appendix B, Criteria XI states, in part, that tests be performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test results shall be documented and evaluated to assure that test requirements have been satisfied.
Contrary to the above, in April 1993, Quad Cities Operating Surveillance (OCOS) procedure 1400-2, Revision 1, ' Monthly Core Spray System Motor Operated Valve Operability Test," was performed; however, the test did not incorporate requirements for establishing seat leakage acceptance criteria as required by ASME Section XI, i
(lWV 2100). Additionally, the test did not document or evaluate the results to assure that test requirements were satisfied.
This is a Severity Level IV violation (Supplement 1).
l BEASONS FOR THE VIOLATION:
Commonwealth Edison acknowledges the violation. Prior to August,1993, Quad Cities did not perform seat leakage testing on the Core Spray 1(2)-1402-9A(B) valves.
The station took credit for monitoring annunciators as an indicator of seat leakage.
1 This position was detailed in the station's response to Generic Letter 87-06.
When the response to Generic Letter 87-06 was submitted, Quad Cities had no i
physical means to test the 1(2)-1402-9A(B) valves in the closed posPdor. The only option was verification of valve position utilizing annunciators.
CORRECTIVE S.LEPS TAKEE AND RESULTS ACHIEVEQ; OCOS 1400-2, Monthly Core Spray System Motor Operated Valve Operability Test, and OCOS 1400-8, Quarterly Core Spray System Motor Operated Valve Operability Test were changed on September 18,1993 to record when the high pressure annunciator is received. The annunciator is an indication of leakage, but does not allow for quantification.
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ATTACHMEN f NOTICE OF VIOLATION INSPECTION REPORT 50-254(265)/93025 i
C&RRECTIVE STEPS TAKEN ANE RESULTS ACHIEVER;(Cont'd)
Based upon discussions with General Electric it is known that a very minor leak (much less than 1 gpm) past the seat of the 1(2)-1402-9A(B) valve would cause the volume to pressurize because of the small volume of incornpressible fluid between the 1(2)-
1402-9A(B) and 1(2)-1402-25A(B). Therefore, verification of valve position utilizing annunciators is an inaccurate indication of valve integrity.
Past inspections performed on the 1-1402-98 and 2-1402-9B showed no abnormal conditions or malfunctions of the valves' internals.
A method to quantify leakage was recently developed. Seat leakage testing that was performed on 1(2)-1402-9A/B for Unit 2 on September 11,1993 and for Unit 1 on November 6,1993. Test results showed that the valves were seating acceptably. All four of the check valves passed the acceptance criteria of leaking less than 1 GPM at a differential pressure of - 1000 psig.
r CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
The revised check valve test is being written as a permanent procedure (OCTS 820--
- 12) and is expected to be completed by December 31,1993. The test requirement to perform the High Pressure Seat Leakage Test each refueling outage will be added to the next revision of IST Program which is expected to be submitted by March 31, 1994.
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DATE WHEN FULL. CRMPLIANCE WAS ACHIEVED:
Full compliance was achieved on November 6,1993, when seat leakage tests were
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successfully completed for the Core Spray check valves.
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