ML20067C272
| ML20067C272 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/06/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9102120008 | |
| Download: ML20067C272 (7) | |
Text
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oowners Grove. Hlinois 60515 February 6, 1991 Mr. A. Bert Davis Regional Administrator - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Two Level IV Violations Inspection 50-254/90022; 50-265/90021 NBC_Do.cLe.LNos. 50d54_anLSD:7Ji5 Reference T.J. Kovach (CECO) letter to A. Bert Davis (NRC),
dated February 1, 1991, transmitting the response to a Notice of Violation Mr. Davis:
The attached response supercedes the Response to Hotice of Violation attached to the reference letter.
The response attached to the referenced letter, due to an oversight, did not include the first page of the response, llopefully, this-has not caused any inconvenience.
If your staff has any questions concerning this letter, please refer them to Rita Radtke, Compliance
' Engineer at 708/515-7284.
Very_truly yours, MWa.>(
T. J. Kovach Nuclear Licensing Manager i
cc:
L.N. Olshan, Proj?ct Manager - NRR T. Taylor. Senior Resident Inspector h
NRR Document Control Dest l
FEB 7 1991 L
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Quad Clties-Nuclear Power Statton Operating Licenses DPR-29 and DPR-30, o
Section 3.B. states that "the licensee shall operate the facility in accordance with the Technical Specifications".
a.
Unit 1 Technical Specification 3.12.F.2 requiras all penetration fire barriers protecting safety related areas be intact or else a continuous fire watch must be established.
Contrary to the above, for approximately six weeks ending on September
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c 20, 1990, the Unit 1 cable tunnel access hatch was open without a continuous fire watch being established..A fire watch in 20 minute intervals was performed during this time.
b.
Unit 2 Technical Specification 4.12.8.1.d requires each Fire Suppression System be demonstrated operable at least once per year by cycling each testablesvalve in the flow path through.at least one complete. cycle of full - travel.-
Contrary 1to the-above, from April 20,1989 to January 2,1990, Unit 2
-sprinkler. system valve number-2-4199-72 exceeded the Technical
-Speciflcation requirement, in that, it was not cycled to verify coperability.
c.
Unit 1 Technical Specification Table 4.8-1 requires the licensee to take a radiological effluent sample within'24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a thermal power
. level change exceeding.20% of rated thermal power in one hour.
-Contrary.to the n ove, on July 2, 1990, a v2diological effluent sample was not:taken when1 Unit.1: power level was. raised more than 20% of rated c
thermal power in one hour. '
d..
Technical-Specification-Table 4.1-1 footnote [2.1 states than an Instrument: check shall be performed on high;steamline radiation once~per shift.
-Contrary to-the above, on August 12 and August'14, 1990c the once per shift instrument check of the main steam line radiation monitors was no_t performed.
e.
Unit _1 Technical Specification 4i3.F requires that prior'to entering' Economic Generation' Control.(EGC) and once per shift while operating in EGC, the EGC operating parameters be reviewed for acceptability.
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_ Contrary-to the above, on November 14, 1990, the licensee discovered that-the Core Monitoring Code that provides the EGC operating parameters had not beei, run and, threfore, reviewed, for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> L
while.the unit was operating in EGC.
Together,= these examples are considered a Severity Level IV violation (Supplement I).
(No. 50-254/90022-01 (DPR);~50-265/90021-01(DPR))
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- Dl11M111.QD As required by 10 CFR 50.73, Licensee Event Reports (LERs) have been submitted to address the above five examples of missed or improperly performed Technical Specifications surveillances.
The corrective actions that have been taken and the associated results achieved, as well as the corrective actions that wlit be taken to avoid further violations for each individual event are included in the LERs.
Cortgetive Action 1 The Quad Cities LERs that specti cally address each example cited in the Notice of Violation ate as follows:
EXAMPLE _a LER 254/90-020 EXAMPLE h LER 265/90-002 E M dP1 L c LER 254/90-014 EXAMPLE d LER 254/90-019 EXAMPLE o LER 254/90-027 The Station recognized potential problems with ensuring Technical Specification surveillances are met and took the initiative to review their general surveillance (GSRV) program.
During the fourth quarter of 1990, the Station requested the Onsite Nuclear Safety Department to conduct an cssessment of the GSRV program.
That assessment is complete and recommendations have been made.
Reviewing the examples in aggregate, we identified a potential common factor which is related to personnel errors.
Based on the knowledge gained from the Onsite Nuclear Safety assessment, the fol!owing corrective actions were developed which are broad-scoped and go beyr,nd those corrective actions to address each event individually.
1 SNLD713te
CORRECTIVE ACTIONS TO PREVENT FURTHER NONCOMPLIANCE 1)
The GSRV Coordinator will provide a listing of Technical Specification surveillances for discussion at the Plan-of-the-Day meeting to keep station management informed of surveillance scheduling, including due dt?.es, when grace periods are entered, and how much grace is left for each surveillance.
This began on January 28, 1991.
2)
A policy will be established and implemented to emphasize management expectations that unless extenuating circumstances exist, the routine use of the surveillance grace period will be eliminated and all GSRV scheduled Technical Specification surveillances will be completed on or before the due date.
The Production Superintendent will develop the polley statement by February 15, 1991.
3)
A Surveillance Coordinator position for the Operations Department will be established by May 1, 1991.
During the interim the Station Surveillance Coordinator from Hork Planning will oversee the Operations Department Surveillance Coordinator duties.
4)
Personnel who perform Technical Specification surve16.ances will receive training on the importance of completing surveillances on time and-paying attention to detail through the completion of the surveillance.
The Station will use the INPO "self-check" program as a guide for developing a lesson plan.
The lesson plan is expected to be completed by March 1 1991 and training is expected.to be completed by May 1, 1991.
5)
The Technical Specification surveillance matrix currently maintained by Regulatory Assurance wil? he incorporated into the GSRV program by July 1, 1991.
6)
A verification of the GSAV Tech Spec database will be performed for completeness and accuracy.
A verification for the Operations Department will be completed by July 1, 1991, and by June 1, 1991 for all other departments.
7)
The Personnel Error Evaluation Presentation (PEEP) Program was established in Jcly 1990.
The PEEP program brings the personnel
' involved in an event and upper station management together for a face to face discussion of the event.
The event is reviewed, facts are presented, conclusions are drawn and proposed corrective actions are discussed.
Examples a and e of this violation were presented as PEEP program events.
In the future, all events which include personnel error as one of the primary causes will be-reviewed by the Station Hanage for the determination if a PEEP will be conducted.
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11 ELD 713 / 9 i
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, O DATE-HHEN FULL.CQMPLIANCE NfLL BE ACHIEVED '
(for each Individual example)
EX&h1E.LE_A full compilance was achieved on September ~20. 1990 when continuous fire watches were established for all required areas.
t EXAMPLE'b full'compilance was achieved on January 2, 1990 when valve 2-4199-072 was cycled, proving operabillty-and satisfying Technical Specification requi remen t s. --
EX6tiP_LL.E Full compliance was achte.ved on July 4, 1990 when a reactor water sample verified no-increase in activity levels,
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= EXAMPLE d l
' Ff ': compilance was ' achieved on-August 14, 1990 when the required instrument i
ch' ks per properly completed, EXAbf1La 4
Full compilance was achieved on November 4,' 1990 when a new Co.e Performance
--. Calculation was completed,:the autosonttoring function of the Core Monitoring Code was-restored, and the Quallfled Nuclear Engineer completed-thermal limits si eticulattons.
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I Y10MILOJL2 10 CFR 50,: Appendix B, Criteria XVI states, in part, that measures shall be established-to assure that conditions adverse to quality-such as deficiencies and non-conformances are promptly identified and corrected.
These measures shall assure that the_cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, on October 4,1990, it was identified that corrective actions for a previous Notice of Violation concerning the adequacy'of work instructions (NRC Violation No. 89022-02a,' did not preclude repetition of a similar event.
On October 4, 1990 a violation for inadequate work
!nstructions concerning lifted leads left unlanded for #3 and #4 turbine-coatrol valve fast acting solenold valves was identified.
This is a repeat violation concerning electrical. maintenance work nu kage content and ins 1 ructions.
This is a Severity Level IV violation (Supplement I).
-(No.=50-265/90021-02(DRP))
QISCUSSION On Oct>ber 3,1990 Quad Cities Unit Two was operating in the RUN inode at approximately 32 percent of rated core thermal power.
At 1650 he' rs, while performing the-Turbine Control Valve Fast Closure Scram Instrums station Functional-Test, Turbine Control Valves (TCV) #3 and #4 failed to fast close Land provide a half-scram-on Reactor Protection System (RPC) Channel 'B'.
The
~#3 and #4 TCV test permissive lights de-energized.-and valve position indicators:showed full: closed.
TCVs #1: and #2 tested satisfactorily.
The fast-action solenoids provide fast closure-(less than one second) of the turbine, control-valves to protect the turbine from overspeed when the load 1s removed. The purpose of the scram is to anticipate the rapid increase in the pr?ssureland_ neutron: flux which may result from the fast closure of.the turbine; control valves.
The failure of TCVs #3 and #4-to fast close and provide a half-scram was due lo~thir fact that the wires to the coils of the fast-acting solenoids were not landed inside the local--junction box located on-the respective control valves.
The cause for-the lifted'lcads was due to a management deficiency in the 8:lectrical Halntenance (EH) Department.
The Hork Packages initiated to perform the work did not provide for adequate documentation of lifted leads.
.A contributingicause was the fact that the "As left Condition-Hork Performed" section of QAP. -1500-S28 was not properly completed uy the EH Individual who lifted the leads, llad this been completed properly, it would have provided an indication to the subsequent EH crews that the leads were lifted and to reland L
iem upon installation of the rebuilt solenoids.
The junction box covers were reinstalled after the leads were lifted to remove the;old'solenold valves.
This is standard maintenance practice.
Therefore, there was no' visual evidence-that the leads in the junction boxes were 117 cd. With the junction.bcx covers-replac:d and no documentation of Ilfted t
'eWs in the work package, a different crew completing the work did not c
b recognize an_ incomplete circuit.
Therefore, leads lifted at the local
~ junction bores wee not relanded after installation of the rebuilt solenoids.
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_ CORRECTIVE ACTj0HS TAKEN AND RES1)LTS ACHIEVED
-The lifted leads for the FASVs on TCVs #3 and #4 were relanded in their respective jun: tion boxes on October 3, 1990, i
CQRRECTIVE ACTIONS TAKEN TO PREVENT FURTHER NON-COMPLIANCE i
1)
An Electrical Halntenance (EH) procedure, QCEM 700-14, " Lifting and
-Landlug Leads", wal-written to outline the steps required for lifting and= landing leads whtn necessary to perform maintenance work, This was L
completed on Nover. Der 16, 1990, i
2)
EH work analysts have been instructed to include a Lead Lift and Land Log Sheet in EH work. packages to properly document laad lifts and lands 1-at locations other than those at the device beir.
r vlaced.
L 3)
EH personnel have been trained on the " Lifting and Landing Leads" procedure.
L 4)
.EH personnel have also been trainn on the importance of properly l
filling out QAP 1500-S28, Work Request History FU,m.
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All Halntenance personnel will review this event at their weekly tailgate meetings by February 6, 1991, 6)-
A Personnel Error Evaluation Presentation (PEEP) was held on October 22 i
.1990.
The event wss reviewed and as a corrective-action the use of a l
Llead lif t and Land Log sheet was proposed, i
t 7)
-Development of a'Halntenance Department "Hork Analyst Guideline" was begun in July _1990.
This guide will aid the analyst in_ preparing maintenance work packages.
The guideline will be issued by February 28.
-1991 and training completed by March 31, 1991.
Previous' corrective actions placed emphasis on verification of,fleid l
condi tions. The lead:, tere properly lifted, however, documentation of_the lifted leads was inadequete.
With the addition of the Lead Lift and Land Log Sheet:and training of Electrical Maintenance personnel on its use,
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Cosmonusaith-Edison'is confident that the recurrence of_this event will be prevented.
-DATE WHEN FULL COMPLIANCE HAS ACHIEVED Full compliance was achieved on October 4, 1990 after the leads had beer relanded,' the test successfully completed, and outage report terminated.
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