ML20063B838
| ML20063B838 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/27/1994 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9402030049 | |
| Download: ML20063B838 (3) | |
Text
dL-Comm::nwscith Edison
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1400 Opus Place Downers Grove, tilinois 60515 q
y January 27,1994 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk
Subject:
Quad Cities Power Station Units 1 and 2; NRC Docket Number 50-254 and 50-265; NRC Inspection Report Numbers 50-254(265)/93031
Reference:
Edward G. Greenman letter to R. Pleniewicz dated December 30, 1993, transmitting Notice of Violation.
Inspection Report 50-254/93031; 50-265/93031 Enclosed is Commonwealth Edison's response to the Notice of Violation (NOV) transmitted with_ the referenced letter. The NOV cited one Severity Level IV violation, pertaining to a failure to follow procedure resulting in a partialloss of shutdown cooling on Unit 1. In order to focus the. appropriate station resources to. respond to comments -
enclosed in the _ referenced letter, the station requests a meeting with the NRC Region ill to obtain further clarification.
The following commitments are being made by this letter:
1)
Procedure OOS 005-1 will be revised to include a checklist for shutdown conditions by March 11,1994.
2)
Procedure OCAP 1100-12 will be revised to clarify guidance concerning craft capability by March 15,1994.
If there are any questions or comments concerning this letter, please refer them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287 Resp ctfully, D. L. Fa.rar, Manager Nuclear Regulatory Services -
' Attachment cc; J. Martin, Regional Administrator, Rill C. Patel, Project Manager, NRR T. Taylor, Senior Resident inspector, Quad Cities mv.unerrenced=mn ver"
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VIOLATION:
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-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 t
Appendix A.1.c included administrative procedures, general plant operating procedures, and procedures for startup, operation, and shutdown of safety related systems.
Quad Cities Operating Procedure (OCOP) 1000-5, " Shutdown Cooling Operation,"
requires the "18" reactor recirculation pump is off and shutdown cooling is discharging to the "B" reactor recirculation loop.
Contrary to the above, on November 11,1993, with Unit 1~ shutdown cooling discharging into the "B" reactor recirculation loop, the "1B" reactor recirculation pump suction valve open, and the "1B" reactor recirculation pump off, control room operators opened the "1B" reactor recirculation pump discharge valve.
This is a Severity Level IV violation (Supplement 1).
B.EASON FOR THE VIOLATION; j
CECO acknowledges the violation. The SCRE and the NSO involved in this event failed i
to recognize the affect of opening the recirculation pump discharge valve on the operation of the Shutdown Cooling System. They also focused their attention on l
ensuring that the recirculation loop differential temperature limit (which was not applicable at this time) was met. Because of this, they believed that additional guidance was needed for complstion of the activity. In their attempt to determine the correct position for the valve, the SCRE and the NSO utilized the position of the A recirculation pump discharge valve instead of reviewing all appropriate (recirculation system and Shutdown Cooling system) procedures. Because the A recirculation pump discharge-valve had beer' opened previously during the outage, the SCRE and the NSO believed that the proper position for the valve was the open position.
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. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED-l
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The MO 1-202-5B valve was closed and normal shutdown cooling system operation was re-established. A precaution was added to the Recirculation system shutdown procedure providing guidance on suction and discharge valve positioning when l
shutdown cooling is in operation.
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A reenactment of this event was included in simulator training to demonstrate the impact of recirculation pump discharge valve position on shutdown cooling capability.
This training was included in Session 7 of the 1993 Licensed Operator requalification training.
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'i Disciplinary action was administered to the SCRE and the NSO involved in this event because of their failure to follow appropriate procedural guidance and their failure to recognize the affect their actions would have on proper shutdown cooling system operation.
QOEBliGTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
t Control Room Shift Turnover procedures will be revised to include a checklist tailored for shutdown conditions. This will provide for better plant status awareness and turnover information during outage periods. The new checklist will require surveillarice and-logging of items such as reactor water temperature, reactor water level, RHR system status, electrical distribution system status, etc., which are important parameters for minimizing shutdown risk. The procedure revision will be implemented by March 11, 1994, prior to the upcoming Unit One Refueling Outage.
The Operations Manager has held personal discussions with all Shift Engineers to discuss his expectations with regard to the craft capability section of OCAP 1100-12,
" Procedure Use and Adherence Expectations." QCAP 1100-12 will be revised to clarify -
the guidance concerning craft capability by March 15,1994.
As described in the cover letter of your inspection report, your investigation also identified weaknesses with procedures, drawings, shift turnovers, operator log practices, and inadequate training for shutdown conditions. Corrective actions for these items are on-going.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved on March 15,1994, following completion of the corrective steps identified above.
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