ML20101S490
| ML20101S490 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/12/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9207170165 | |
| Download: ML20101S490 (4) | |
Text
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.'... 'N Commonwealth Edison l
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Downers Grov3. Illinois 60515
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June 12,1992 c
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- U.S Nuclear Regulatory Commission
- Washington, D.C. 20555 Attention: Document Control Desk
Subject:
Quad Cities Nuclear Power Station linits 1 and 2 Response to Notice of Violation inspection Report Nos. 50-254/92011; 50-265/92011 NRC Docket Nos. 50-254 and 50-265 Referance: B. Clayton letter to Cordell Reed dated May 14,1992, transmitting NRC Inspection Report 50-254/92011; 50-265/92011 Enclosed is tha Cornmonwealth Edison Company (CECO) response to the Notice of Violation (NOV) which was transm!tted with the reference letter and Inspection Re:> ort. The NOV cited one Level IV violation with two examples of events associated wit 11nadequate procedures. CECO's response is provided in Attachment A.
If you staff has any auestions or comments concerning this response, please contact Jim Watson, Compliance Engineer at (708) 515-7205.
Sincerely, k$.
Er T.J. Kovach Nuclear Licensing Manager Attachment cc:
' A.B.~ Davisi Regional Administrator-Region lli'-
L. Oishan, Project Manager, NHR T. Taylor, Senior Resident inspector l
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AiTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92011; 50-265/92011 ylOLATION: (254/92011-01a and 01b) 10 CFR, Part 50, Appendix B, Criterion V recluires, in part, that activities affecting quality shall be preacribed and accomplished in accordance with instructions of a type appropriate to the circumstances, which shall include acceptance criteria for determining that important activities have been satisfactor0y accomplished.
Contrary to the above; a.
Work instructions for the February 6,1991, repair for the high pressure coolant injection (HPCI) turbins 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 hydroetatic test, was not a type appropriate to the circumstance. The procedure failed to provide steps to assure that the temperatuo at all vessellocations during hydrostatic testing were maintained equal to or above the limit required by Techreical Spechication 3.6.B.1 as shown in the appropriate curve of Figure 3.6-1.
This is a Severity Level IV Violation (Supplement 1).
t REASON FOETHE VIOLATI.Olt (254/92011-01a)
Concerning the issue relaNa to the HPCI turbine stop valve, CECO acknowledges the vioisiun. The cause of the event was due to inadequate work instructions during a previous overhaul of the valve in February 1991. During this woik, a crack was discovered in the weld joining the po pet guide to the valve cover during disassembly and inspe% ion of the valve.
he weld was repaired in I
the field. The welding
.osed the guide to become oval shaped and to lose perpendicularity with tne bonnet. No dimensional verifications or alignment cl ecks 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.
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e ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92011;50-265/92011 COBBEGILVESIEES_TEENANDEESULTSACHIEVED: {254/92011-01a)
The Unit 1 HPCI sicp valve poppet guide end cover were replac3d, The stop valve was reassembled and tested.
O-8 ebruary 19,1992, OCOS 2300-1, " Periodic HPCI Pump 09erability Test,"
wac.;uccessfully completed and HPCI was declared operable.
C.OBRECTIVE STEPO TO AVOID FURTSEB_VlOLSTION:(254/92011-01a)
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 reassembly has been reviewed for the presence of proper tc erance criteria. This review was completed it' April 1992. From this review, no work packages were identified as requiring additional tolerance criteria.
ThN event was reviewed wPh Ouality Control personnel, Mechanical Maintenance Work Analysts and Engineering Construction per3onnel cautioning them to look for proper tolerances during reassembly of critical co nponents.
l DAT.E WHEN FULL COMPLIANCE WAS ACHIEVER:(254/92011-01a)
Full compliance was achieved on February 19,1992, when the HPCI system was successfully tested and declared operable.
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ATTACHMENT A
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92011;50-265/92011 REASON FOR THE VIOLATION: (254/92011-01b)
Concerning the issue relative to Un't 2 vessel hydrostatic test, CECO acknowledges the violation. The cause of this event is personnel error. The Shitt Engineer performing the test also wrote piocedure OCOS 201-7, " Reactor Vessel and Class 1 Systems Ten Year Hydrostatic Test." He understcod the RPV pressure / temperature curve requirements. The actual temperature points,
. > wever, 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 aoints, and inadec uacia in the HLA program which did not require a dedicated ariefing of the evo ution for subsequent shifts.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED: (254/92011-01b)
The test was suspended and immediate actions were taken to restore the RPV to within the required temperature / pressure range of the technica! specification.
The performance of the Shift Engineer was reviewed and appropriate disciplinary action was administered.
O_QHBE_CTIVE STEPS TO AVO_ID FURTHER VIOLATION:(254/92011-01b) l The procedure OCOS 201-7, along with OCOS 201-4, " Reactor Vessel and
- Primary Systems Leakage Test," will be revised to clearly state which thermocouples are essential during the performance of these two procedures.
This revision will also provide a better method to document at what interval the thermocouples are to as monitored and the minimum thermocouple temperature requirements. A note will be nided to make personnel aware of the effect that the cool water can have on RPV temperature when the GRD system is started.
These procedures will be revised prior to use.
The HLA program will be revised to require 1) dedicated briefinp of the evolution for subsequent shifts,2) a discussion of each briefing of the limitations and actioris, and 3) clear lines of authority and responsibility (e.g. parameter l
monitoring, for tho HLA evolution. Program revisions will be corrpleted 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 reflect these guidelines.
DAIE WHENJd!LL COMELIAND_E WAS ACL-ilEYER:(254/92011-01b)
Full compliance was achieved on March 29,1992 when the RPV temperature / pressure was restored to the technical specification requirements.
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