ML20059G180

Notice of Violation from Insp on 930821-0930.Violation Noted:During Operability Surveillances on Both Unit HPCI Sys,Surveillance Procedure Inadequate in That Appropriate Info to Direct Valve Manipulations Were Not Contained

ML20059G180
Person / Time
Site:	Quad Cities
Issue date:	10/26/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059G155	List: IR 05000254/1993025 ML20059G152 ML20059G180
References
50-254-93-25, 50-265-93-25, NUDOCS 9311080027
Download: ML20059G180 (3)

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1 NOTICE OF VIOLATION ,

Commonwealth Edison Company Docket Nos. 50-254; 50-265 Quad Cities Station, Units 1 and 2 License Nos. DPR-29; DPR-30 I

During an.NRC inspection conducted on August 21 through September 30, 1993,.  !

four violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1993), the violations are listed below:

1. 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.l.c included  ;

administrative procedures, general plant operating procedures, and  ;

procedures for startup, operation, and shutdown of safety related i systems,

a. 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, j

b. Nuclear Operating Directive N00-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 r considerations, and the results of surveillance testing.

Contrary to the above, the diesel generator preventive maintenarice -i (PM) program failed to include several vendor recommended PM i activities. Examples included vendor recommendations for i replacement of lower liner seals and cylinder head to liner water i grommets.  ;

This is a Severity Level IV Violation (Supplement I). {

2. 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 ar.d 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. ,

i Contrary to the above, corrective actions taken to ensure performance of a self-check 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: i 9311000027 931026 PDR ADDCK 05000254 G PDR  ;

Notice of Violation 2 P

a. On. September 3, 1993, a nuclear shift operator started the 1A residual heat removal (RHR) pump instead of RHR service water pump during a surveillance activity; t

b. 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.

l This is a Severity Level IV violation (Supplement 1).

3. 10 CFR 50.72 (b)(ii)(B) requires that a notification be made for any

• event or condition that results in the nuclear power plant being in a l condition that is outside the design basis of the plant.

Contrary to the above, on August 21, 1993, a notification was not made to the NRC when the emergency diesel generator exciter panel'was found outside of the design basis. The panel was not seismically mounted' to_

• the floor.

This is a Severity Level IV violation (Supplement 1).

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4. 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 l that test requirements have been satisfied.

Contrary to the above, in April 1993, Quad Cities Operating Surveillance (QCOS) 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, (IWV 2100). Additionally, the '

test did not document or evaluate the results to assure.that test requirements were satisfied.

1 This is a Severity Level IV violation (Supplement 1).

Pursuant to tiie provisions of 10 CFR 2.201, Commonwealth Edison 'is hereby required to submit a written statement of explanation to the U.S. Nuclear ,

Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555 with a copy to the U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy to the NRC 1

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Notice of Violation 3 Resident Inspector at the Quad Cities Nuclear Station within 30 days. of the date of the letter transmitting this Notice of Violation (Notice). This reply.

should be clearly marked as a " Reply to a Notice of Violation" and should -  :

include for each violation: (1) the reason for the violation or, if '

contested, the- basis for disputing the violation, (2) the corrective steps' .

that have been.taken and the.results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply.is not received within.the  ;

time specified in this Notice, an order or a demand for information may be ~

issued as to why the license should not be modified, suspended, or revoked, or i why such other action as may be proper should_not be taken. Where good cause ,

is shown, consideration will be given to extending the response time.  :

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J Dated at Glen Ellyn, Illinois this j2k day of October 1993 )

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