ML20083C880
| ML20083C880 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/15/1995 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ESK-95-066, ESK-95-66, NUDOCS 9505230041 | |
| Download: ML20083C880 (6) | |
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21710 2Gsth Asenoc North 03rdova, II 61242 9710 Tel.krHis 1-22 41 ESK-95-066 May 15,1995 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION:
Document Control Desk
SUBJECT:
Quad Cities Power Statior Units I and 2; NRC Docket Number 30.!54 and 50-265; NRC Inspection Report Mumbers 50-254(265)/94029
REFERENCE:
- 11. B. Clayton Letter to E. S. Kraft, Jr., Dated April 14, 1995, Transmitting Notice of Violation Enclosed is Commonwealth Edkon's (ComE4's) response to the Notice of Violation transmitted with the referenced letter. The level IV violation concerned Out-of-Service Problems (six examples) that had occtered a: the station.
The following commitments are contained ir. this letter:
Review of all existing pre-prepared DOSS.
Review of all existing OOSs currently hanging in the field. - (254-200-95-031005) - In Progress - Due Date-7/12/95 Perform Station Training to applicable departments (Supplemental to immediate Corrective Action where the Station Manager stated expectations, with handouts, to Department Ileads who then tailgated this information to the workers). -
(254-200-95-031008) - In Progress - Duc Date - 6/14/95) 9505230041 950515 PDR ADOCK 05000254 Q
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' ESK-95-066 1
If there are any questions or comments concerning this letter, please refer them to Nick Chrissotimos, Regulatory Assurance at (309)654-2241, extension 3100.
i Respectfully, dd /(-
E. S. Kra af J Site Vice President Quad Cities Station i
Attachment cc:
J. Martin, Regional Administrator, Rill R. Pulsifet, Project Manager, NRR C. Miller, Senior Resident inspector, Quad Cities l
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5 U.S. Nuclear Regulatory Commission Page 3 ESK-95-066 VIOLATION 50-254/265-94029-Ol(A-F) l j
During an NRC inspection conducted on December 16, 1994, through January 25,1995, a
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violation of NRC requirements was identified. In accordance with the " General Statement of
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Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the following violation is listed below:
Technical Specifications Section 6.2.A requires that procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, shall be established and implemented.
Appendix A of Regulatory Guide 1.33 included plant procedures for maintenance that can affect safety-related equipment.
I Quad Cities Administrative Procedure 230-4, Revision 5, " Equipment Out of Service,"
e step D.I., required that all vent and drain valves repositioned during an out of service should have out of service cards placed on the valves to assure proper repositioning during the return to service.
Contrary to the above, on or about December 15, 1994, operators repositioned one hundred and seventy-one vent valves for a maintenance related out of service on the Unit I control rod drive system without placing out of service cards on the vent valves.
Quad Cities Administrative Procedure 230-4, Revision 7, " Equipment Out of Service,"
step D.7.c, required that once an additional out of service (AOOS) is prepared, "The reviewer will list any ESF actuations, equipraent trips, containment breeches, special draining considerations or any other operational concerns associated with the AOOS."
Step D.7.e required a second reviewer to " verify that cards being added will not l
jeopardize any primary or secondary containment."
Contrary to the above, on or about January 14, 1995, an AOOS attachment to out of scivice (OOS) No.16796 was issued without the reviewer or second reviewer listing or l
verifying the effects on secondary containment of opening the 1/2 diesel generator (DG) day tank wet pipe fire system test valve, 2-4199-90TES.
1
S U.S. Nuclear Regulatory Commission Page 4 ESK-95-066 On February 26 the Unit 1/2 emergency diesel generator (EDG) tripped due to high cooling water temperature during an operability surveillance. When the 1/2 EDG was loaded, the diesel generator cooling water pump (DGCWP) feed breaker from Bus 18 tripped, and the alternate feed breaker from Bus 28 failed to close. The licensee identified that the power source select switch for the DGCWP was selected to Bus 18 following an unrelated maintenance activity. The select switch was a three-position switch; BUS 18, NORMAL, and BUS 28. With the switch out of the NORMAL position, the 1/2 EDG would be inoperable to one of the two units. Following maintenance on the DGCWP, the return-to-service preparer did not include instruction to place the switch back in the NORMAL position due to the upcoming refueling outage on Unit 2. Quad Cities Administrative Procedure (QCAP) 230-4, " Equipment Out Of Service," required that components be returned to service to the normal standby line-up position. Failure to restore the 1/2 diesel generator cooling water pump power select switch to normal standby position is an additional example of a previous Violation (50-254/265-94029-Olc) of Technical Specification 6.2.A.
During a subsequent EDG operability surveillance, Unit 1/2 EDG tripped again. The licensee identified that the racking screw collar for the DGCWP breaker was not in the normally full out position. This resulted in a mechanical trip signal which prevented the breaker from closing. The equipment attendant indicated that the racking screw collar appeared to be in the full out position when the bus was returned to service.
Understanding and training on returning breakers to service appeared to be lacking.
On March 4 a non-licensed operator isolated the backup nitrogen system prior to valving in the backup instrument air system. Responsibility for coordinating operator actions for OOSs recently shifted from the center desk operator to the shift foreman.
Lack of familiarity with OOS assignments and a weak OOS document contributed to this event. Quad Cities Administrative Procedure (QCAP) 230-4, " Equipment Out Of Service," required the center desk foreman to dispatch personnel as necessary to remove equipment from service in correct sequence. Failure to specify the correct sequence for performing this OOS is an additional example of a previous Violation (50-254/265-94029-Old) of Technical Specification 6.2. A.
On March 6 an operator isolated the normal torus suction to the 2A core spray pump without aligning an alternate suction path for the associated keep fill pump, resulting in the pump operating for some time without a suction path. The shift foreman did not review the special instructions with the operator assigned to perform the OOS. Failure to implement the QCAP 230-4 is an additional example of a Violation (50-254/265-94029-Ole) of Technical Specification 6.2. A. The licensee planned to inspect the keep fill pump for damage during the current outage.
N U.S. Nuclear Regulatory Commission Page 5 ESK-95-066 On March 8 while taking the 2B core spray pump OOS electrically, the pump was inadvertently operated for about a minute without a suction path while the pump bowl was drained. Prior to racking out the pump's breaker, an operator removed the trip and close control power fuses. To ensure the breaker was tripped, the operator was required to push the " trip" push button on the breaker. liowever, the operator pressed the "close" push button. This action closed the breaker and started the pump. After realizing the error, the operator tripped the breaker locally. Contrary to QCAP 230-4, the foreman failed to specify the correct sequence to the operator while placing the 2A CS pump OOS. The pump seal was damaged and will be replaced during the current outage. Failure to follow the OOS procedure is an additional example of a Violation (50-254/265-94029 01f) of Technical Specification 6.2.A.
This is a Severity Level IV violation (Supplement 1).
REASONS FOR TIIE VIOLATION Comed acknowledges the violation. The apparent root cause for the events involved Human Performance. The errors concerned procedure adherence and failure to self check.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Individual investigations were initiated for the identified events; however, additional events which occurred between March 8 and March 13 prompted the station to take a more aggressive approach to the OOS process as a whole. This aggressive approach reviewed all OOS problems dating back to August 1993, included all open investigations and reports concerning the OOS process. Additionally, where a normal investigation has 45 days to be complete, the review was performed with immediate corrective actions implemented in 5 days.
The station has taken the following actions to address the root cause in response to the above events:
1.
On March 13, all work involving Out of Service (OOS) was stopped except by approval of the Station Manager.
2.
A tem was assembled to review and recommend corrective actions for work involving OOSs. This review occurred from March 14 to March 17.
3.
Work resumed on March 17 with immediate corrective actions in place.
4.
Meeting was held with NRC on March 23 to communicate station actions regarding OOS crrors.
U.S. Nuclear Regulatory Commission Page 6 ESK-95-066
- 5.
Final Report on OOS Performance was issued on March 29,1995.
6.
Review of OOS Commitments and Open OOS Investigations complete on April 6, 1995.
CORRECTIVE STEPS TAKEN TO AVOID FURTilER VIOLATION The Station is planning on taking or has taken the following actions:
Perform a trend review of OOS problems in order m determine if these corrective actions are effective (NTS# 254-200-95-031001) - Complete Implement an OOS Preparation Form (Communication Center). - (254-200-95-031002)
- Complete Implement an OOS Briefing Form (Control Room) (Pre-Job Brief for each OOS). -
(254-200-95-031003) - Complete Implement Independent Verification - Apart-in. Action - (254 200-95-031004) -
Complete Review of all existing pre-prepared OOSs. Review of all existing OOSs currently hanging in the field. - (254-200-95-031005) - In Progress - Due Date-7/12/95 Implement OOS procedure revision. - (254-200-95-031007) - Complete Perform Station Training to applicable departments (Supplemental to Immediate Corrective Action where the Station Manager stated expectations, with handouts, to Department licads who then tailgated this information to the workers). - (254-200 031008) - In Progress - Due Date - 6/14/95)
Use of OOS Procedure Use of PPC Cards Expectations / Accountability - Reinforced, as needed, by Senior Station Mgmt.
Establish a Grounding Procedure and train applicable departments on proper use. -
(254-200-95-031009) - Complete DATE WilEN FULL COMPLIANCE WILL BE ACillEVED Full Compliance was met with the actions taken prior to recommencing OOS work. - 3/17/95 i
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