ML20065L028

Responds to NRC Re Violations Noted in Insp Repts 50-254/90-14 & 50-265/90-14.Corrective Actions:Procedure Qos 1000-2 Revised

ML20065L028
Person / Time
Site:	Quad Cities
Issue date:	11/13/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9012050165
Download: ML20065L028 (6)

Text

. . . _ _ _ _ _ . . . . .

O Crmmtnnealth Edistn Pgl 1400 Opus Place hh

. 'V Downers Grove, Utinois 60s15 (

- November 13, 1990 L

)

Mr. A. Bart Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road i Glen Ellyn, IL 60137

[

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation Contained in Inspection Report 50-254 265)/90014 1 - EC_Donttlou50-151.md_50-2E5 H.D. Shafer to Cordell Reed letter dated

~

Reference:

m October 5, 1990.

Mr. Davis:

The referenced letter transmitted Inspection Report 50-254/90014 and 50-265/90014 which contained two (2) Netites of Violation. The first violation related to the lack of acceptanca criteria contained in an Operating Surveillance procedure. The second violation cited that appropriate design reviews were not performed in 1978 during installation of permanent test leads to perform the Emergency Core Cooling Systems (ECCS) simulated automatic actuation and diesel generator automatic start surveillance.

Quad Cities Station acknowledges that some procedures are weak and has initiated a resourte intensive program to upgrade procedures. The delineation of appropriate acctptance criteria in procedures is included in the Procedure

- Writer's Guide and is an important aspect to the Procedure Upgrade Program.

Since 1978, Commonwealth Edison's Modification Program M s undergone significant improvements. One important improvement to the program is a more thorough definition of mdifications. He blieve that the improved modification program (which heightened tN awareness of work requiring engineering review) should prevent futwe recurrence of the installation of the equipment.without proper design reviews.

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{ NOV 16 WIKI

9 Mr. A.B. Davis November 13, 1990  ;

An extension to this re:ponse was requested by Commonwealth Edison.

The extension was granted by H. Shafer, Branch Chief.

Very truly yours,

.J. vach Nuclear Lic nsing Manager cc: Document Control Desk L. Olshan, Project Manager H. Shafer, Branch Chief J. Hind Section Chief T. Taylor, Senior Resident Inspector TK/RS/Imw 2NLD605/3

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, RESPONSE TO NOTICE OF VIOLATION 254/90-014-01 Y10LAl10E 10 CFR 50, Appendix B, Criterion XI in part states that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents.

Contrary to the above, monthly operability surveillance . ting was performed on the Residual Heat Removal System / Low Pressure Coolant injection (LPCI) pumps in accordance with procedure QOS 1000-2, Revision 12, Residual Heat Removal System (RHRS) Pump Operability, which did not contain any acceptance limits to demonstrate that the LPCI pumps were able to perform their design function.

This is a Severity Level IV violation.

BACKGROUND Commonwealth Edison concurs that surveillance procedure QOS 1000-2, " Residual Heat Removal System Pump Operability" does not contain sufficient acceptance criteria to determine the acceptability of the surveillance procedure.

Technical Specification 4.5.A.3 defines the testing requirements for the LPCI mode of the RHR system which includes a monthly pump operability test, a quarterly flow rate test (which defines the acceptance criteria of 9000 gpm per division against a system head corresponding to a reactor vessel pressure of 20 psig) and a simulated automatic actuation each refueling outage. The combination of these three (3) tests demonstrate the system can meet its design function. Each individual surveillance demonstrates an important-aspect of the design function.

Technical Specification bases 4.5, paragraph 2 states, "To increase the l

i availability of the individual components of the core and containment cooling system the components which make up i.ne system, i.e., instrumentation, pumps, valve operators, etc., are tested more frequently. The instrumentation is functionally tested each month. Likewise, the pumps and motor-operated valves are also tested each month to assure t%1r operability." Commonwealth Edison has interpreted these bases to require that a " functional" test of the pumps is required monthly. The " functional" pump test requires that the pumps start l and provide flow to the system. Verification of the 9000 gpm flow per l division is, therefore, not required during the monthly test. This is further l validated through paragraph 3 which discusses the required surveillances during out-of-services. The paragraph states "The agree of operability to be demonstrated depends on the nature of the reason for the out-of-service l equipments. For routine out-of-service period caused by preventative

' maintenance, etc., the pump and valve operability checks will be performed to demonstrate operability of the remaining components. However, if a failure, design deficiency, etc., cause the out-of-service period, then the demonstration of operability should be thorough enough to assure that a

similar problem does not exist on the remaining components. For example, if an out-of-service period is caused by a falltle of a pump to deliver rated capacity due to a design deficiency, then other pumps of this type might be subjected to a flow rate test in addition to the operability checks." The acceptance criteria for the monthly operability test will therefore ensure that a " functional" test of the pumps are satisfactorily performed.

The Operating Department has reviewed all Emergency Core Cooling System (ECCS) operating surveillance procedures. The review determined that the lack of acceptance criteria was limited to this operating surveillance procedure.

Remaining ECCS surveillance procedures were found to have adequate acceptance criteria.

ACTION TAKEN 10 CORRECT THE DEFICLEMCY 005 1000-2, Residual Heat Removal System Pump Operability, has been revised to include acceptance criteria. The revision was approved on October 10, 1990.

COMECIIVE ACTIONS TAKEN TO PREYENT FURTHE!LNQRCOMPLI ANCE Quad Cities Station is in the process of upgrading Station procedures. The Procedure Upgrade Program is accomplished through the guidance contained in the Procedure Writer's Guide. This writer's guide requires that app,*opriate acceptance criteria be included in the procedures. Also, the verification checklist for the upgraded procedure (which is used for review of the procedure) requires that acceptance criteria be included in the upgraded procedure. All ECCS surveillance procedures are scheduled to be upgraded by December 31, 1990. Completion of the Procedure Upgrade Program is scheduled for 1996.

In the interim, all Technical Specification surveillance procedures will be reviewed by March 5, 1991 to ensure adequate acceptance criteria is included in the surveillance procedures. The procedures, which are identified to be deficient through this review, will be revised by June 5, 1991.

DAIL}l HEN FULLCQtiELIARC.EELLBE ACHIEVED full compliance was achieved on October 10,1990 when 0051000-2 was revised to include acceptance criteria.

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RESPONSE TO NOTICE OF VIOLATION 254/90-014-02 Y10Lall0B 10 CFR 50, Appendix B, Criterion III in part states that: " Design changes, including field changes, shall be subject to design control measures commensu ate with those applied to the original design and be approved by the organ 17atlon that performed the original design unless the applicant desionates another responsible organization."

Contrary to the above, on April 28, 1978, the licensee installed wiring behind the Unit I control room panels that connected auxiliary contacts for Emergency Core Cooling Systems (ECCS) and Emergency Diesel Generators (EDGs) to a common test point on a terminal strip behind the 901-5 panel. The installation was performed without doing the required design change reviews.

This is a Severity Level IV violation.

DlScus.5108 Quad Cities Station accepts the Notice of Violation in that permanent test leads were installed in 1978 without proper engineering reviews.

In order to conduct surveillance procedures QTS 1100-1 and QTS 1100-3, Unit I and Unit 2 Emergency Core Cooling System (ECCS) Simulated Automatic Actuation and Diesel Generator Automatic Start Surveillance, temporary test leads were installed f am all required test points in the Control Room to a test recorder, sn April 28, 1978, Work Requests 1232-78 and 1233-78 were written to permanently install the test wires to streamline the performance of the test. Since the installation of the permanent configuration was not performed under the modification program, adequate design reviews were not performed.

On August 29, 1990 at 1736 hours0.0201 days <br />0.482 hours <br />0.00287 weeks <br />6.60548e-4 months <br />, the Corporate Engineering and Construction Department notified the Station that both units were potentially outside of the design basis (since electrical divisional separation for ECCS was violated). The installation of the permanent test leads, which were connected to the logic circuitry of Division I and II ECCS equipment, were landed to the same terminal strip in the 901(2)-5 panel. A twenty-four hour shutdown Limiting Condition for Operation requirement was entered, as specified by Technical Specifications 3.5.A.6 and 3.5.B.S.

l 5AFETY SLGHLELCANCE The divisional separation criteria for electrical systems in the control room is designed to prevent failure of the ECCS equipment in both divisions due to a fire of missiles (from rotating equipment). Since there is no rotating equipment in the Control Room, the missile failure mechanism is not a concern. Damage due to a fire has been evaluated under the Appendix R evaluation. In this evaluation, the control room was assumed to be damaged.

Modifications have been installed as a result of the evaluation to assure the l reactor can be shutdown to a cold condition independent of the equipment located in the control room. The safety significance of this violation is minimal.

ZNLD605/6

. 1 ACHORS TAKEN TO CORRECT THE DELICIENCY The test leads installed in panels 901(2)-3, 901(2)-5 and 901(2)-8 were removed under work request Q86872. The 1/2 Diesel Generator test leads were terminated for Unit 2 under temporary alteration 90-1-20. The removal of the i diesel generator test leads will be accomplished during an outage of '

sufficient duration for 1/2 Diesel Generator.

CORRECIIYE_ACI1ONS TAKEfL10lREYERLLURIHEfLCOMEll&MCE Since 1978, Commonwealth Edison's modification program has-been significantly revised. Internal evaluations, as well as the NRC's SSOMI at Dresden and Zion, identified that work was not properly classified as modifications. As a result, a new modification program was developed. The new modification program better defines when the modification program is required to be implemented.

The Operating Engineer is required to classify the work, i.e., whether the work constitutes a modification. The Technical Staff Supervitors provide assistance (when requested) to the Operating Engineer for the classification of the work. With the better definition of a modification, personnel should properly classify modifications and therefore, this type of occurrence should be prevented in the future.

Procedures OTS 1100-1 and 1100-3 will be revised to require temporary installation of test leads to accompitsh the test. The procedures will be revised by 12/31/90.

DAILHRENJALCOMELIANCE WAS ACHIEVED Full compliance was achieved at 0810 hours0.00938 days <br />0.225 hours <br />0.00134 weeks <br />3.08205e-4 months <br /> on 8/30/90 when the test leads were removed and all systems were declared operable.

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