ML20070G458
| ML20070G458 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/11/1994 |
| From: | Campbell G COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GGC-94-102, NUDOCS 9407200112 | |
| Download: ML20070G458 (9) | |
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6 Quad Cities Nuclear Power Station 22710 206 Avenue North
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--m Cordova. lihnois 61242 9740 kj Telephone 309'654-2241 l
GGC-94-102 July 11, 1994 i
U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington. D.C.
20555
SUBJECT:
Quad Cities Nuclear Power Station Units 1 and 2 l
NRC Docket Number 50-254 and 50-265 NRC Inspection Report Numbers 50-254(265)/94010
REFERENCE:
E. Greenman letter to E. Kraft dated June 14. 1994, transmitting Notice of Violation Inspection Report 50-254/94010; 50-265/94010 Enclosed is Commonwealth Edison's response to the Notice of Violation (NOV) transmitted with the referenced letter. The NOV cited one Level IV violation with three examples concerning Work Control at Guad Cities.
The following commitments are being made by this ietter:
l 1.
The Operations Department will revise OCAP 230-4 (Equipment Out of Service) to establish that only operators can hano. relocate, or remove out-of-service cards. The revision will also clarify the l
role of the maintenance supervisor in verifying the points of_
isolation listed on the out-of-service are proper for the work being performed.
Operations Department shall accomplish this item by 10-1-94 (NTS # 2651809400704).
2.
OCEM 200-4 (Molded Case Circuit Breaker Inspection and Test for Non E0 Breakers) is in the process of being revised to incorporate the l
changes contained in IP 646.
This interim procedure provides i
specific directions to check for potential entry into an LCO for opposite unit equipment and assigns the responsibility for-relocation of out-of-service cards to the Operations Department.
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This procedure will be revised by Maintenance Staff by 9-1-94 (NTS # 2651809400701).
3.
Revise QCMPM 1500-2 to require notification of Operations management prior to taking corrective actions when inspection deficiencies are noted.
This revision is currently in progress and shall be completed by the Maintenance Staff by 7-25-94 (NTS # 2542009401601).
4.
A sampling of other preventive maintenance procedures will be reviewed for similar problems by Maintenance Staff and the required changes submitted by 11-1-94 (NTS # 2542009401602).
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9407200112 940711
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4 If there are any questions or comments concerning this letter, please refer them to Nick Chrissotimos. Regulatory Assurance at (309) 654-2241 ext. 3100.
Respectfully, M
Guy ampbell Stati n ianager Quad C', es Nuclear Power Station GGC/RB/jmk Attachment cc:
J. Martin, Regional Administrator, RIII C. Patel, Project Manager, NRR
- . Miller, Senior Resident Inspector Quad Cities Letterbook i
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1 STATEMENT OF VIOLATION:
During an NRC inspection conducted on March 24 through May 11, 1994, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the j
violation is listed below:
i 10 CFR 50, Appendix B, Criteria V states, in part, that activities affecting quality shall be prescribed by documented instruction of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions.
a.
Quad Cities Administrative Procedure (QCAP) 307-11, Revision 1,
" Preparation and Control of Safety, Regulatory, ASME Code or Reliability Related Maintenance Work Package," step D. 9.b (1), stated, "If applicable, verify points of isolation listed on OOS are proper for work being performed."
l Contrary to the above, on March 17, 1994, maintenance l
personnel moved out-of-service (OOS) tags from the control l
power switch on breaker G2 without verifying the isolation as proper for the work being performed.
b.
Quad Cities Administrative Procedure (QCAP) 307-12, Revision 1,
" Preparation and Control of General Work Request," step D.11.b required workers to perform work as required by the work package.
Work Request Q10018 required work be performed on high pressure coolant injection (HPCI) restricting orifice 1-2301-63C.
Contrary to the above, on March 21, 1994, HPCI restricting orifice 1-2301-63B was inadvertently disassembled instead of restricting orifice 1-2301-63C.
C.
Quad Cities Administrative Procedure (QCAP) 1100-12,
" Procedure Use and Adherence Expectations," Revision 3, step D. 6.b. (3), stated that correct usage of procedure included ensuring applicable prerequisites are met.
Quad Cities Preventive Maintenance (QCMPM) procedure 1500-2, "RHR Service Water Vault Submarine Door Preventive Maintenance," which governed an activity affecting quality, 1
required in step E.1 that a shift engineer review plant conditions to support scope of work and authorize start of work.
Contrary to the above, on March 21, 1994, the seal on the j
Unit 2B residual heat removal (RHR) service water vault door j
was replaced without completion of prerequisite step E.1.
This is a Severity Level IV violation (Supplement 1).
Example A - REASON FOR VIOLATION l
As per LER 265\\94-007, this event was caused by an inadequate procedure, an Operations knowledge deficiency, and inadequate work practices in Electrical Maintenance (EM).
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
1.
Operations Department personnel conducted a walkdown of Unit 1 MCCs and ensured remaining out-of-services did not affect i
Unit 2 Technical Specification operability.
2.
On April 11, 1994, this event was discussed in a safety
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meeting of the Electrical Maintenance Department. This tailgate meeting emphasized the need and purpose for a
supervisors to verify points of isolation listed on the.out-of-service are proper for the work being performed. During 3
this tailgate meeting, EM personnel ~were. notified that out-l of-service cards would only be relocated by Operations personnel.
3.
The Maintenance Superintendent sent'a letter '(TMK-94-027) to
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all maintenance personnel directing that all out-of-service card moves, placements, or changes be made expressly by.
Operations personnel (or under the direct observation of Ops personnel).
4.
On April 16, 1994, an interim procedure change (IP 646)~was approved for QCEMS 250-11 (General Electric Model 7700 Motor Control Center EQ Maintenance and Surveillance) which requires Operations to authorize start of work separately on each cubicle. This interim procedure provides specific directions to check for potential entry into an LCO.for opposite unit equipment and assigns the responsibility for relocation of out-of-service cards to the Operations Department. The IP 646 changes were incorporated in.a revision to QCEMS 250-11, effective 6-22-94.
1 5.
A Maintenance Department Memorandum (700-01) was written and j
issued on 4-28-94 detailing a pre-job checklist for all i
Safety, Regulatory, and ASME Code work packages. This pre-job checklist lists verification, walkdown, and a pre-job brief, including the out-of-service.
CORRECTIVE ACTIONS TO PREVENT FURTHER OCCURRENCE:
1.
The Operations Department will evaluate the training for personnel who prepare or review out-of-services and take any necessary corrective actions to ensure the scope of work for maintenance inspections and the potential impact of these surveillances on the plant is clearly communicated.
Operations Department shall accomplish this item by 10-1-94 (NTS # 2651809400702).
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4 2.
Maintenance will communicate their expectations on the proper use of warnings, cautions, and notes in procedures by 8-1-94 (NTS # 2651809400703).
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3.
The Operations Department will revise QCAP 230-4 (Equipment Out of Service) to establish that only operators can hang, relocate,.or remove out-of-service cards. The revision will also clarify'the role of the maintenance supervisor in
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verifying the points of isolation listed on the out-of-service are proper for the work being performed. Operations Department shall accomplish this item by 10-1-94 (NTS #'
2651809400704).
4.
QCEM 200-4 (Molded Case Circuit Breaker Inspection'and' Test for Non EQ Breakers) is in the process of being revised to incorporate the changes contained.in IP-646. This procedure will be revised by Maintenance Staff by 9-1-94 (NTS #
1 2651809400701).
i DATE WHEN FULL COMPLIANCE WILL BE MET:
Full compliance was achieved when the station reinstalled the breaker, tested.the room cooler,.and exited the LCO.
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Example B - REASON FOR VIOLATION:
As per the-problem investigation report (PIR # 2542009401700) the-cause of the Mechanical Maintenance (W4) worker disassembling RO (restricting. orifice) 1-2301-63B.instead of 1-2301-63C was due to inadequate use of self checking techniques.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
1.
RO 1-2301-63B was reassembled.
2.
Work request Q16007 was initiated to inspect RO 1-2301-63B to ensure that the component receives a documented disassembly and inspection.
l-3.
The cognizant Mechanical Maintenance Department (;MMD)
Foreman (recently promoted to that position) was temporarily
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relieved of his Foreman duties and underwent one-on-one i
training with the MMD General Foreman and MMD Master Mechanic. The training involved work-process' requirements, management expectations, Regulatory.and Quality Assurance requirements. The training was completed prior to: allowing the MMD Foreman to resume his duties Eus Foreman.
4.
The identification tabs on.the two orifices were cleaned of-l l
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5.
On 4-14-94, Maintenance Departments implemented pre-job briefing and a pre-job checklists (Maintenance Memo # 700-01). This includes identifying the proper equipment prior to the start of the job.
6.
The Mechanical Maintenance Department reviewed this report with personnel at a tailgate meeting. The meeting focused on management expectations relative to self checking prior to any job evolution. The need for prompt problem identification (PIF process) and proper notification to maintenance and operations supervisors when a work error or an operability issue occurs, was also addressed. This item was completed on 5-17-94 (NTS # 2542009401701).
I CORRECTIVE ACTIONS TO PREVENT FURTHER OCCURRENCE:
The corrective actions taken above should be sufficient to prevent any further violations of-this event in the future.
DATE WHEN FULL COMPLIANCE WILL BE MET:
Full compliance was achieved with the re-assembly of the 1-2301-63B restricting orifice, f
Example C - REASON FOR VIOLATION:
As per Problem Investigation Report 1-94-016, Mechanical l
Maintenance personnel failed to follow the requirements of the procedure and procedure QCMPM 1500-2 is deficient in its current layout.
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l CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
1.
A Local Leak Rate Test was performed on the door and it was found' acceptable.
2.
The daily and outage schedules for other preventive maintenance activities which do not require an out-of-service have been reviewed through the end of Q1R13 to verify that the procedures / work requests used have the proper controls.
3.
Any preventive maintenance work performed prior to the review outlined in 2 above has been reviewed by Maintenance First Line Supervision.
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4.
' Problem Investigation Report 1-94-016 has been reviewed by all Maintenance First Line Supervisors, Maintenance craft i
personnel, and Operations Department personnel through tailgate sessions after the event.
CORRECTIVE ACTIONS TO PREVENT FURTHER OCCURRENCE:
1.
Revise QCMPM 1500-2 to require notification of Operations management prior to taking corrective actions when inspection deficiencies are noted. This revision is i
currently in progress and shall be completed by the 1
Maintenance Staff by 7-25-94 (NTS # 2542009401601).
2.
A sampling of other preventive maintenance procedures will be reviewed for similar problems by Maintenance Staff and the required changes submitted by 11-1-94' (NTS #
2542009401602).
DATE WHEN FULL COMPLIANCE WILL BE MET:
Full compliance was met on 03/27/94 with the station's entry into the administrative LCO for the 1/2 Diesel Generator.
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SUPPLEMENTAL INFORMATION The June 14, 1994 NRC letter (Docket Nos. 50-254; 50-265) to E.
Kraft from Edward G. Greenman, stated that our response should address how weaknesses in our work control process will be corrected to ensure that: operators are made aware of degraded equipment availability caused by maintenance, post maintenance testing is performed in a timely manner, and the out of service tagging system is functioning to provide personnel safety and equipment integrity.
In addition to the actions stated with each of the specific problems listed above, the following in place processes and practices address the concerns expressed by the NRC:
1.
QCAP 307-10 (Work Request Initiation / Classification /
Cancellation Procedure) requires that if any Technical Specification equipment is or could be affected by the performance of the proposed work, then it is indicated on the front of the work request. If an actual LCO (Limiting Condition of Operation) will be entered during performance of the work, the applicable Technical Specification paragraph number is to be referenced on the work request.
2.
When an LCO is to be entered, Operations personnel initiate a QCOS detailing the necessary actions during the LCO and actions needed to exit the LCO. The QCOS is displayed on a board in the Shift Engineer's office. These are reviewed by each shift as they come on.
3.
During the daily Plan of the Day meetings, LCOs are brought up for status update.
4.
During shift turnovers (which have Operations and work group personnel in attendance), work to be performed during the upcoming shift is reviewed so that all groups in attendance can be cognizant of the work.
5.
Maintenance groups have been conducting pre-job briefs that have included operations personnel on a more frequent basis.
6.
Work packages that require post maintenance testing are segregated by system and reviewed by Operations personnel to see when testing is to best be accomplished (prior to start prior to system hydro, during operation, etc.).
up, 7.
The Station's Heightened Level of Awareness Program (QCAP 200-11) establishes a policy that identifies critical tasks and specifies the precautions to be considered prior to performing these tasks.
8.
The Station's Overview Policy (QCPP 2405) was effectivc 5-2-94.
The policy establishes standards for managers and
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- supervisors to spend time performing overview activities.
These standards are intended to ensure that the actions of
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managers and supervisors are consistent with published site values, and that they are reinforcing these values with the personnel they superviee.
9.
The Station implemented Self-Check procedure QCAP 2300-28 on 7-1-94. The self-check process is a work practice in which a worker consciously and deliberately reviews the intended action and expected response before performing a task.
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