ML20097F956
| ML20097F956 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/12/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206160188 | |
| Download: ML20097F956 (4) | |
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N Ccmmsnwealth Edis:n
/ 1400 opus Place I
Downers Grove, Illino's M515 June 12,1992 U,S Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation inspection Report Nos. 50 254/92011; 50 265/92011 NRC QQRket Nos. 50-254 and102265
Reference:
B. Clayton letter to Cordell Reed dated May 14,1992, transmitti NRC In?pection Report 50-254/92011; 50-265/92 11 Enclosed is the Commonwealth Edison Con nm JECo) response to the Notice of Violation (NOV) which was transn.?~1.ith the ie;crence letter and inspection Report. The NOV cited one LevelIV violation with two examples of events associated wit 1 inadequate procedures. CECO's response is provided in Attachment A.
If you staff has any questions or comments concerning this ',sponse, please contact Jim Watson, Compliance Engineer at (708) 515-7205.
Sincerely, b $. hw Ge T.J. Kovach Nuclear Licensing Manager Attachment cc:
A.B. Davis, Regional Administrator-Region lil L. Olshan, Project Manager, NRR T. Taylor, Senior Resident inspector 9206160188 920612 PDR ADOCK 05000254 G
PDR ZNLD/1731/7
ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92011;50-265/92011 VJOLAIlOR (254/92011-01a and 01b) 10 CFR, Part 50, Appendix B, Criterion V rec uires, in part, that activities affecting quality shall be prescribed and accomplishec in accordance with Instructions of a type appropriate to the circumstances, which shall include acceptance criteria for determining that important activities have been satisf actorily accomplished.
Contrary to the above:
a.
Work instructions for the February 6,1991, repair for the high pressure coolant injection (HPCI) turbine stop valve were not a type appropriate to the circumstances. The instructions failed to include requirements to assure adequate clearances between the poppet guide and valve poppet during valve repairs resulting in a subsequent HPCI stop valve failure, b.
The surveillance procedure used during the March 29,1992, Unit 2 vessel hydrostatic test, was not a type appropriate to the circumstance. The procedure failed to provide steps to assure that the temperature at all vessel locations during hydrostatic testing were maintained equal to or above the limit required by Technical Specification 3.6.B.1 as shown in the appropriate curve of Figure 3.6-1.
This is a Severity Level IV Violation (Supplement 1).
BEASORfDE_THE_VJOLAIlOR (254/9201101a)
Concerning the issue relative to the HPCI turbine stop valve, CECO acknowledges the violation. The cause of the event was due to inadequate work instructions during a previous overhaul of the valve in February 1991.. During this work, a crack was d,scovered in the weld joining the poppet guide to the valve i
cover during disassembly and inspection of the valve. The weld was repaired in the field. The welding caused the guide to become oval shaped and to lose perpendicularity with the bonnet.. No dimensional verifications or alignment checks were requested or stated in the work instructions prior to or after the welding work was finished. This condition caused galling and the valve to become stuck open during a subsequent HPCI valve stroke test.
ZNLD/1731/8
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ATTACHMENT A 4
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50 254/92011;50 265/92011-k
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CORBEGILVE_SIEESlAKEN.AND BESULT.SACHIEVED: (254/92011-01a) -
j The Unit 1 HPCI stop valve poppet guide and cover were replaced. The stop.
valve was reassembled and tested.
1 On February 19,1992, QCOS 2300-1, " Periodic HPCI Pump Onerability Test,"
was successfully completed and HPCI was declared operable, l
COBBEGILVESTEESlORQlD_EUBIBERMOLAILON : (254/9201 1 -01 a)
A work analyst guideline has been prepared as a supplement to the existing-procedure and issued to aid the work analyst in completing work packages. This guide was issued in April 1991.
)
A sample of Unit 2 work packages performed by' contractors involving detailed j
reassembly has been reviewed for the precence of proper tolerance criteria, This review was completed in April 1992. From this review, no work packages were identified as requiring additional tolerance criteria.
This event was reviewed with Ouality Control personnel, Mechanical Maintenance Work Analysts and Engineering Construction personcal cautioning them to look l
for proper tolerances t uring raaseembly of critical components.
b DATE WHENf_ULLC.OMPLIANDE.WAS ACHlEMEQ:(254/92011-01a)--
l Full compliance was achieved on February 19,1992, when the HPCI system was; successfully tested and declared operable.
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1 4
r ZNLD/1731/9 7
ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92011; 50-265/92011 BEASOtLEOHIBE_YlOLaIlON: (254/92011-01b)
Concerning the issue relative to Unit 2 vessel hydrostatic test, CECO The Shift acknowledges the violation. The cause of this eve l
RPV and Class i Systems Ten Year Hydrostatic Test," He understood the i ts aressure/ temperature curve requirements. The actual temperature po n,
li ce with the minimum required temperature. Contributing ca t
re lack of V temperature specific guidance in the OCOS 201-7 procedure fo d dicated oriefing of the evolution for subsequent shifts.
(254/92011-01b)
C_QBBECILVE_SIEESIAKENAND_BEEU1ISACHIEYED:
The test was suspended and immediate actions were taken to fi ti within the required temperature / pressure range of the technical spec The performance of the Shift Engineer was reviewed and appro action was administered.
CO.BBECllY. EEIEESTHAYQlR.fURTHEB_VIOLAIJOB T
The procedure OCOS 201-7, along with OCOS 201-4, " Reacto Primary Systems Leakage Test," will be revised to clearly state which thermocouples are essential during the performance of these two pro This revision will also arovide a better method as monitored and the minimum thermocouple temperature ht requirements. A note will be added to make pers i
t td These procedures will be revised prior to use.
i The HLA program will be revised to require 1) dedicated briefings for subsequent shifts,2) a discussion of each briefinr of the limitatio a
actions, and 3) clear lines of authority and responsibility (e.g. paramete for the HLA evolution. Program revisions will be completed by Ju monitoring) Additionally, OTA 010-4," Preparation, Performance, and Re Special Operational Tests," will also be revised by July 31,19 31,1992.
- guidelines, YER
- (254/92011-01b) s
, StiEILEULLHOMELlaNCEMASACHIE
$9mpliance was achieved on March 29,1992 w j
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92011;50-265/92011 BEASQtLEQBlHEMOLAIlott (254/92011-01b)
Concerning the issue relative to Unit 2 vessel hydrostatic test, CECO acknowledges the violation. The cause of this event is personnel error. The Shif t Engineer performing the test also wrote procedure OCOS 201-7, "Reector Vessel arid Class 1 Systems Ten Year Hydrostatic Test." He understood the RPV aressure/ temperature curve requirements. The actual temperature points, lowever, were insufficiently monitored during the test to assure compliance with the minimum required temperature. Contributing causes of the event were lack of specific guidance in the OCOS 201-7 procedure for monitoring RPV temperature Doints, and inadec uacies in the HLA program which did not require a dedicated 3riefing of the evo ution for subsequent shifts.
CQBBEGIly_E_S_T_EPS TAKEN AND_RES_ULIS ACHIEVED; (254/9201M1b)
The test was suspended and immediate actions were taken to restore the RPV to within the required temperature / pressure range of the technical specification.
The performance of the Shift Engineer was reviewed and appropriate disciplinary action was administered.
COBBECIIVfLSIEES_T_QAV.QlD_EURTHER VIOLAHON: $54/92011-01b)
The procedure OCOS 201-7, alon with OCOS 201-4, Reactor Vessel and Primary Systems Leakage Test," ill be revised to clearly state which thermocouples are essential during the performance of these two procedures.
This revision will also 3rovide a better method to document at what interval the thermocouples are to as monitored and the minimum thermocouple temperature requirements. A note will be added to make personnel aware of the effect that the cool water can have on RPV temperature when the CRD system is started.
These procedures will be revised prior to use.
The HLA program will be revised to require 1) dedicated briefings of the evolution for subsequent shifts,2) a discussion of each briefing of ths limitations and actions, and 3) clear lines of authority and responsibility (e.g. parameter monitoring) for the HLA evolution. Program revisions will be completed by July 31,1992. Additionally, OTA 010 4, " Preparation, Performance, and Review of Special Operational Tests," will also be revised by July 31,1992, to reCect these guidelines.
DATE.WH EtLEULLC_QMELI ANQfLWASAACHI EYE R: (254/9201 1 -01 b)
Full compliance was achieved on March 29,1992 when the RPV a
temperature / pressure was restored to the technical specification requirements.
ZNLD/1731/10 j