ML20092M061
| ML20092M061 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/24/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9202270141 | |
| Download: ML20092M061 (6) | |
Text
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Ccmmonwealth Edison.
A,
- 1400 opus Place Downers Grove, luinois 60515
,.b February 24,1992 U.S. Nuclear Regulatory Commission Document Conial Desk Washington, D.C. 20555
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation inspection Report Nos. 50 254/91024; 50-265/91020 NRC Docket Nos. 50 254 and 50 265
Reference:
E.G. Greenman letter to Cordell Reed dated January 24,1992 transmitting NRC Inspection Report 50 254/91024; 50 265/91020 Enclosed is Commonwealth Edison Company's (CECO) response to the subject Notice of Violation (NOV) which was transmitted with the referenced letter and -
Inspection Report. The NOV cited two Level IV violations related to a failure to make appropriate 10 CFR 50.73 Reports for two events and for inadequate procedures. ' A Level V violation was also cited for failure to adhere to procedures for wearing electronic dosimeters.
If your staff has any questions or comments concerning this letter, please refer them to Perry Barnes, Compliance Supervisor at 70S/515-7278.
l Very truly yours, i
T.J.
ach
-- Nuclear Licensing Manager Enclosure L
cc:
A. Bert Davis, Regional Administrator - Region'lli L. Olshan, Project Manager, NRR -
T. Taylor, Senior Resident inspector - Quad Cities
'l O'7 fl0 /12 9202270241 920224
[DR ADOCK 050oo254
/
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ENGLOSURE RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50 254/9.1024;50-265/9_1020-VIOLAllONR5R91024-Olah) 10 CFR 50.7b tai (2) (v) requires that any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to remove residual heat, regardless of the plant mode or power level, and regardless of the significance of the structure, system, or component that initiated the event be repor1ed to the NRC.
Contrary to the above:
a.
On April 24,1991, during performance of a surveillance activity the reactor core isolation cooling system (RCIC) pump discharge valve (1-1301-49) failed to open. This event was not reported to the NRC.
b.
On December 1,1991, during valve stroking activities the RCIC pump discharge valve (1-1301-49) failed to open. This failure was not reported to the NRC.
DEASONEOBlllE_ VIOLATION These two instances where the RCIC 1-1301-49 valve failed to open were not reported to the NRC because of a misunderstanding on how to interpret the enteria for 10 CFR 50.73 (a)(2)(v). Operating De aartment personnel did not apply the additional guidance provided by Section 7 of 9UREG 1022 Supplement 1. In this NUREG under question 7.9, it states that these events should have been reported regardless of operating mode or power level. This information is l
contained in the discussion section for the 10 CFR 50.73 (a)(2)(v) reporting criteria in OCAP 1780-3, " Deviation Report / Licensee Report / Deviation investigation Report". Operations personnel failed to review this information when lley made their determination on reportability, in the instances involved, the RCIC system was out of service at the time of discovery or the plant was in a condition where RCIC was not required to be operable. Because the system was not operable at the time of the event, the reportability was thought not to apply.
l CORBEGIlYE.SIEESIAKENAND_BESU LTS. ACHIEVf D t
1 The April 24,1991 failure and the December 1,1991 failure will be reported to the NRC by Licensee Event Reports.
1 A review was conducted of the Deviation Reports written from 1990 to February 24,1992, where the reactor was in Modes 1 or 2. This review identified two additional events that were mis-classified and should have been reported under 10 CFR 50.73(a)(2)(v). These events will be documented as License Event Reports and submitted to the NRC by March 24,1992.
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d COB B EGIIVE.SIEESlHAI_WJLL.Q E TAK ENIO.AV.QlD_EUBIH ERVIOLAI1 OMS A committee, consisting of representatives from various departments was initiated on January 27,1992, to review station events on a daily basis. This includes reviewing these events for reportability to the NRC.
A letter has been sent to Operating Manaoement personnel providing clarification of the 10 CFR 50.73 (a)(2)(v) reporting crileria.
These events and the NOV will be covered in the next license retraining sessions.
R AIE_WH EN.EULLCOMELI AhlC E_WJ LLB EAGlilEYER The Licensee Event Reports will be completed by March 24,1992, i
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V10LATIONJ25_4/91024-02)
Quad Cities Technical Specification 6.2.B, Plant Operating Procedures requires that radiation control procedures be maintained, made available to all station personnel, and adhered to.
Contrary to the above, on November 20 and 26,1991, electronic dosimeters assigned to personnel working in the radiological control area were found unattended, and not worn as required by ORP 1001-1, Rev.10.
NOTE: NOV lists ORP 1001-1, however, this ORP does not exist. The referenced procedure should be ORP 1000-1.
BEASON_EQfLT13E_VJOLATION Actions by the individual involved in the event were contrary to station policy and procedures.
COBBECJ1VE_SIEPS_ AN D_B EEllLIAACBIEVER The specific incidents have been discussed with the individuals by their supervisors.
CORRECIIVERIEES THAT WILLBElAKENIO_AEQlD_EUBIEER VIOLATJON a.
A letter was distributed to station personnel on January 13,1992, discussing the proper use of dosimetry. Department supervisors will discuss this letter at future "taligate" sessions, b.
A copy of the same letter described above was reprinted in the station outage newsletter on January 15,1992. This newsletter is distributed to personnel entering the plant.
c.
A separate letter was distributed to Radiation Protection personnel which described the proper response and documentat!on of lost domisetry events.
This letter was also diccussed at a *ta'! gate" session to ensure ccit Radiation Protection personnel understand management's expectations or, tub issue.
RAIE WHELLEULLCOMPl. LANCE _WJLLBEACBIEVER Full compliance was achieved when the Individuals involved were counseled on performance expectations by their supervisor, i
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VIOLATlON I254/91024-05a b) 10 CFR Part 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed and accomplished in accordance with instructions of a type appropriate to the circumstances, which shallinclude acceptance criteria for determining that the activities have been satisfactorily accomplished, Contrary to the above:
a.
On September 22,1991, the return to service instructions utilized to return the Unit 2 reactor recirculation system motor-generator sets deluge fire protection header isolation valves (2-4199174,2-4199-175) to service did not appropriately prescribe repressurizing the fire headers after they had been isolated anc drained, b.
On December 9,1991, the out of service instructions utilized to secure the 1 A and 2A primary containment purge fan isolation dampers did not appropriately prescribe the orientation the dampers were tc be secured in, nor did the instructions contain acceptance criteria for deter mining or verifying the activity had been satisfactorily accomplished.
BEASONEQBlHE.MQLATION a.
Reactor Recirc MG Set Deluge The Unit 2 reactor recirc MG set deluge system was taken out of service (OOS) to repair isolation valves in the system. The OOS was accomplished by closing a fire header isolation valve upstream of the deluge valves. When the return to service was performed, the fire header was pressurized without first pressurizing the deluge valve latching chamber whicll is necessary to keep the valve closed. The return to service instructions on the Master OOS checklist did not list the necessary sequence to achieve this result, b.
Secondary Containment Boundary The 1 A and 2A Drywellfforus Purge Fans were taken out of service on l
December 8,1991, to perform filter replacement and sealing of the duct work. The OOS required securing the suction and discharge dampers in the l
closed position. The dampers were instead secured in the open position-l resulting in a pathway from secondary containment when the ductwork was opened. This was caused by inadequate verification of damper position due to lack of damper position indication.
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CORBECTIVE_SIEESlAKEN ANQ BESULIS ACHIEVER a.
Reactor Recirc MG Set Deluge This event has been tailgated to the operating crews to inform them of the cause of the deluge and the need to be aware of this potential condition, b.
Secondary Containment Boundary The purge fan damper linkages were secured OOS in the closed position.
The remainder of the work on the system which required opening the ductwork was identified as a Heightened Level of Awareness activity to assure adequate controls and precautions were in place. Opening of the purge ductwork was treated as an opening of a secondary containment penetration.
CORBEGILVESTEESJHAT WILL.BEJAKENlDRQ1D_EURTBER_VIOLAILON a.
Reactor Recirc MG Set Deluge Procedure OOP 4100-12, RESTORING PRESSURE TO THE FIRE MAIN, will be revised to include appropriate steps to pressurize deluge valves when refilling fire headers that have been Isolation and drained, Procedure OAP 300-14, EQUIPMENT OUT-OF SERVICE, will be revised to include a general step for sequencing return to service of fire headers.
Pending completion of procedure revisions, the Fire Marshallis periodically reviewing out of services involving the fire protection suppression system to look for similar configurations and provide guidance for restoration of the system.
This events will be included in licensed and non-licensed operator retraining, b.
Secondary 1cntainmenLBoundary The Drywell/ Torus Purge Fan suction and discharge damper operators have been labeled to indicate open and closed position.
The Drywell/ Torus Purge Fans and filters have been marked as a secondary j
containment boundary.
OCAP 230-5, INDEPENDENT VERFICATION, will be revised to include discussion of the proper method of verification of ventilation damper position.
OCAP 200-11, HEIGHTENED LEVEL OF AWARENESS PROGRAM, will be revised to include reference to Secondary Containment work.
This event and the procedure changes will be included in licensed and non-licensed operator retraining sessions.
DAIE_WHEN.EULkOOMELlANCE_WILLBE ACELE_VER The procedure changes and training will be completed by May 15,1992.
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