ML20085K971
| ML20085K971 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/25/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111010166 | |
| Download: ML20085K971 (5) | |
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l Ccmmonw::lth Edison 1400 opus Place Downers Grove, ilunois 00$15 v
October 25,1991 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50 254/91017; 50 265/91013 i
NRC Docket Numbere 50 254 and 50 265 Referenco:
E. Groonman lotter to Cordell Reed dated September 25th transmitting NRC Inspection Report 50 254/91017;50 265/91013 Enclosed is Commonwea!th Edison Company's (CECO) response to the Notico of Violation (NOV) which was transmitted with the reference letter and insaoction Report. The NOV cited three Severity Level IV violations. The first vio ation concerned the f ailure of COS 0051 " Operations Weekly Summary of Daily Surveillance" to include adequate acceptance criteria to assess instrument operability as required by the Technical Specifications. The second violation concerned 10 CFR 50.59 Safety Evaluations and Scroonings. Finally, the third violation involved the fallure to record the as found secondary containment boundary condition when maintenance was performed on secondary containment components prior to the performance of a test.
if your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Complianco Engineer at (708) 515 7285.
Very truly yours, f
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Nuclear Licenkv irig Manager Attachment cc:
A Bert Davis, NRC Regional Administrator Rill L. Olshan, Project Manager NRR T. Tay*or, Senior Resident inspector 91iidioi65 vii65ti ~
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1 Response to. Notice.ofN1olation NRC Inspection Report 50 254/01017;265/91013 t
e Ylolatio0.3 10 CFR 50. Appendix B, Criterion XVI, in part, states that in the case of significant conditions adverse to quality, moasures shall be established to assure that the cause of the condition is determined and corrective action taken to proclude repetition.
Contrary to the above, on March 5,1991, through July 30,1991, l
corrective actions taken for a previous violation were not adequate to precluc:e repetition. The " Operations Weekly Summary of Daily Surveillance," OOS 0051, used to accomplish the torus narrow and wide range instrument check failed to include adequate acceptance criterit.io assess instrument operability as required by the Technical Specif<uations. This is considered a recurrent example of a previous violation (254/90014 01).
ReasorifoLThe_ Violation Quad Cities acknowledges that procedure OOS 0051 " Operations acceptance criteria to ver!fy (y of Daily Surveillance
- did not contain adequate Department Weekly Summar 1
ne operability of the Instruments monitoring this parameter. This situallon is similar to the one identified in flispection Re > ort 254(265)90014 where it was identified that COS 1000-2 Pesidual Heat Removal did not contain acceptance limits to demonstrate that System Pump Operability'le. The corrective action for that violation encompassed the LPCI pump, as operab l
l-a review of surveillance procedures to verify that acce atance criteria were present.
During this review the station believed that OOS 005< was acceptable because it i
met the Tech Spec definition of an instrument check. An instrument check is defined per the Tech Specs as 'a qualitative determination of acceptabla operabikty by observation of instrument behavior during operation. This-determination shall include, where possible, comparison of the instrument with l
other independent instruments measuring the same variable". OOS 0051 does call for a qualitative comparison of instrumentation but does not offer guidance to the operator as to what values are permissible, therefore the result of the comparison may be subjective, l
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donective_Steplaken and Results Achieved Quad Cities Station issued an operating memo to all licensed personnel aroviding guidance on the performance of instrument checks. Specifically, nstruments wi!I be verified to be within 5% of full scale unless a specific procedure provides other guidance. A nuclear work request will be genarated for mstrumentation that exceed the 5% of scale tolerance. The 5% eriteria will be used for all Tech Spec related instrument checks where specific cnteria is not cpecified in existing procedures.
Conec.tive_ Steps _Taken toAvoid furthetViolation A review of instrument check surveillances will be performed to verify the adequacy of the surveillance acceptance criteila. Changes to appropriate implementing 3rocedures will be made as necessary. This is expected to be completed by March 31,1992.
Date_When EulLCompliance_Will Be..A.ch!eved Full compliance was achieved on October 25,1991 with issuance of the operating memo.
Violation 2 Ouad Cities Technical Specification 6.2.A, Plant Operating Procedures, requires detailed written procedures to be prepared, approved, and adhered to.
Quad Cities Administrative Procedure (OAP) 110012, Revision 5, Conduct of 10 CFR 50.59, Safety Evaluation und Screening, requires that safety evaluations describe low the proposed change will affect equipment failures. In particular, any new f ailure modes and their potential impact durin0 all applicable operating modes shall be addressed. Additionally, this procedure requires safety evaluations to include descriptions of how the change will affect plant operation when the changed structure, system, or component functions as intended.
Finally, OAP.111012 requires the safety evaluations to document why the consequences of the accident (off site dose) associated with the f ailure will not be increased.
Contrary to the above:
a.
The 10 CFR 50.59 Safety Evaluation SE-91341, completed on July 3,1991, did not describe the potential impact of a new failure mode (strainer plugging). The evaluation failed to describe how the potential failure of a strainer would impact system operability during all applicable modes and how the change would affect plant oaerations, particularly the impact on system pump flow t
cl1aracteristics.
b.
The 10 CFR 50.59 Safety Evaluation SE 91331, completed on June 24,1991, did not describe any new failure modes and their potential impact durin0 all operating conditions. Specifically, the potential fai ure of the safety related 4KV bus due to the propagation of a fault from the nonsafety related maintenance and test l
equipment (M&TE) was not addressed.
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c.
The 10 CFR 50.59 Safety Evaluation SE 91314, completed on June 7,1991, did not describe all new f ailure modes and their potentialimpact during all operating modes. The potential failure associated with interfaced non safety M&TE with the torus narrow ran0s pressure Indication (PI) was not adequately addressed, d.
The 10 CFR 50.59 Safety Evaluation SE 91306, completed on June 3,1991, did not adequately describe how the change would affect plant operation when the changed system or component functioned as intended, in that, no operator actions or administrative controls to prevent (or remove) the second SBGT train from operation following a design basis event were considered.
BoosonJottheNiolat!on CECO act nowled0es the four cited safety evaluation examples did not sufficiently detail the safety areas evaluated. We believe that proper safety evaluations were performed but the evaluator failed to document the evolution of the evaluation as required b OAP 1100-12 " Conduct of 10 CFR 50.59 Safety Evaluations and Screenings conective_Stepslaken.and_Besults. Achieved The cited safety evaluations were reviewed and found to have reached the correct result. A meeting was held with the Technical Staff Supervisor, Operating Engineers and Assistant Technical Staff Supervisors to discuss this violat on.
Specifically the four cited examples and other examples of safety evaluations viewed as excellent were reviewed. This limited group of personnel will be responsible for reviewing all safety evaluations until the corrective actions described below are completed. A restricted number of reviewers will be implemented by November 1,1991.
Gotte.cilve_Stepa_TakestoAvoldfurthetViolation To ensure that the performance of the safety evaluation is completely documented, Quad Cities will designate a limited group of Individuals authorized to perform 10 CFR 50.59 safety evaluations. This group will receive additional training on the concepts required for performing safety evaluations as well as training on the transient and accident analyses. Specific examples of deficient and acceptable safety evaluations will be included. Practical verification of the training-objectives will be included in the training process. This group will be established and trained by March 1,1992.
L To ensure adequate management oversight the Onsite Nuclear Safety Group will provide periodic independent reviews of completed safety evaluations at least l
through the second quarter of 1992. This review will be initiated by January 1, 1992.
Date_WhenEulLCompliance_Will BeAchieved Full compliance will be achieved when the safety evaluation review group is implemented. The anticipated date of full compliance is November 1,1991.
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-10 CFR 50, Appendix B, Criterion ll requires, in part, that the licensee implement a quality assurance pro 9 tam throughout plant life. This i
arogram is specified in the Commonwealth Edison's Quality Assurance Program Topical Report, CE t A, Revision 134. Section 2.2 of the i
Topical Report cornmits Quad Cities Nuclear Station to comply with Regulatory Guide 1.33, dstod November,1972, which requires, in part, that the licensee comply with American National Standard institute (ANSI) Standard 18.7-1972.
l ANSI Standard 18.71972 paragraph 6.4 requires that a surveillance test program be prescribed to ensure that safety related structures, systems, anc components will operate to keep parameters within normal bounds, or to place the plant in a safe condition. Additionally, the test procedures shall require reporting the as found condition, and the corrective action date.
1 Contrary to the above, on November 13,1990 and previously, secondary containment capability testing failed to record the as found secondary containment boundary enndition when maintenance was performed on secondary containment components prior to the performance of the test.
Reasonfotthe31olation Prior to the initiation of the secondary containment capability test, smoke t
tests and boundary walkdowns were performed to identify any degraded f
secondary containment barriers. As a result of pre test activities, deficiencies were corrected under the nuclear work request program prior to the aerformance of the t
integrity test. Therefore as found conditions were not recordec.
j Gonectlye_Steplakeaand.BenlisAchieved On August 13,1991, Quad C!tles initiated as found testing of the secondary containment integrity.
Correctlye_SteplaketttoAvoid Eurther31olations Quad Cities will develop a procedure by April 1,1992_which describes activities relating to preventative maintenance on secondary containment boundaries. This procedure will contain instructions on how to perform a walkdown and detail the actions which will be taken when a def ciency is identified.
A secondary containment test will be performed and as found results recorded prior to the start of refueling during the upcoming Unit 2 outage, in the future, the station will perform the secondary containment system test -
and record the as found results pr or to the start of refueling.
QateEhenfujLCompliance_WitLBeAchiev.ed L
Full compliance was achieved on August 13,1991 with the initiation of as l
l found testing.
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