ML20127B330
| ML20127B330 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/08/1993 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9301120248 | |
| Download: ML20127B330 (7) | |
Text
,....
'K Commonwealth Edison
.I.
1400 Opus Place Downers Grove, 'lunois 60515 January 8, 1993 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk Subject-Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-254/92025; 50-265/92025 MRC_DockttaoLJ0-214_and 50-265
Reference:
B. Clayton letter to Cordell Reed dated December 11, 1992, transmitting NRC Inspection Report Nos. 50-254/92025; 50-265/92025 Enclosed is the Commonwealth Edison Company (CECO) response to the Notice of Violation (NOV) transmitted with the reference letter.
The NOV cited two violations involving either an inappropriate procedure or failure to follow procedures. CECO's response to the violations is provided in Attachment A.
The reference letter also requested that we provide a response to an unresolved item dealing with how emerging design issues are resolved.
CECO's response to the unresolved item is provioed in Attachment B.
If your staff has any questions or comments concerning this
)
transmittal, please refer them to Denise Saccomando, Compliance Engineer at (708) 663-7285.
Sincerely, l g /h,<.Wg T.J. Kovach Nuclear Licensing Manager Attachments cc:
A.B. Davis, Regional Administrator - Region III C. Patel, Project Manager, NRR T. Taylcr, Senior Resident Inspector 1200M
'p-( /
11ggg QQ ZNLD/2447-1 4
G l
l
l AUACliMENLA RESPONSE 10 NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92025; 50-265/92025 VIOLAIION:
254(265)/92025-04 10CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality be prescribed by documented instructions of a type appropriate to the circumstances.
Contrary to the above, on October 12, 1992, the instructions for troubleshooting of a ground on the Unit i 125 VDC system, an activity affecting quality, were not appropriate to the circumstarces.
Specifically, the extra shift engineer trecrrectly specified a Unit 2 electrical switch in the Unit 1 troubleshooting M ccedure.
This is a Severity Level IV violation (Supplement 1).
HEASONJORJilE_VIOLAHON:
CECO acknowledges the violation which resulted from personnel error by the extra shift engineer (SE) preparing the ground switch checklist.
During the selection of the switches for troubleshooting the Unit i ground, the extra SE erroneously selected a Unit 2 switch and the checklist was not verified to be correct for the activity.
CORRECTIVE _ ACTIONS _TAKEN _ AND_RESULIS_ACilIEVE01 The Shift Engineer, the Station Control Room Engineer (SCRE), the Center Desk Nuclear Station Operator (NS0) and the Equipment Operator involved in this event were counselled with respect to their performance during the event.
Emphasis was placed on the need to ensure that an independent verification of instructions has been performed prior to implementing the instructions.
Additionally, emphasis was placed on the need to provide all pertinent documentation, including limitations and precautions, to individuals performing activities in the field.
Appropriate disciplinary action was administered to all individuals involved.
CORRECTIVE _SIEESJilATJILLDLIAKEH_T0_ AVOID _EURIllEILVIOLAIIDMS This event was included in a presentation to all Operating Engineers, Shift Engineers and SCREs during an Operating Department Management meeting held on October 14, 1992.
This discussic again emphasized the need for independent verification of instructions and the documentation requirements for activitie' in the field.
No additional corrective actions are deemed necessary at this time.
DATEJHEHlVLLCOMPLIANCE HILLDE_ACilIEVE01 Full compliance was achieved on October 14, 1992, when at an Operating Department Management meeting, the need for independent verification of instructions and the documentation requirements for activities in the field were emphasized.
ZNLD/2447-2
AIIACIMEMLA RESPONSE 10 NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92025; 50-265/92025 Y10LATION;_25M2651/92QZ5-06 10CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality be accomplished in accordance with prescribed procedures.
Contrary to the above:
j a.
From June 1990 through October 1992 twice-weekly and quarterly system walkdowns, an activity affecting quality, were generally not performed in accordance with QTP 010-8, " System Engineer Halkdown Guidelines"; nor were lists of walkdown items prepared and reviewed as required by that procedure.
j b.
As of October 5, 1992, the monthly reviews for 13 temporary alterations were not performed within 4 months of the installation dates as required by Quad Cities Administrative Procedure QAP 300-12, " System Temporary Alterations," Revision 23.
c.
from November 1988 to October 1992, monthly temporary alteration reviews of temporary alterations installed greater than three months failed to address one or more of the concerns as required by the system temporary alterations implementing procedure QTP 300-22, " System Temporary Alteration Review," Revision 4.
This is a Severity Level IV Violation (Supplement 1).
REASOK_E0!LYl0LAll0M; (Example A)
CECO acknowledges that system walkdowns were generally not performed in accordance with procedure QTP 010-8.
Some system engineers were not aware of the requirement for getting approval not to perform system walkdowns. Most system engineers did not reference previous walkdown findings, outstanding work, deficiencies or newly generated work requests.
This is inconsistent with management expectations.
CORRECUXE_SIEPS TAKEM_AMD_RESULILACllIEEEQ1 (Example A)
Discussions were held with the System Engineer Group Leaders about the content of system walkdowns.
The System Engineer Group Leaders are reviewing walkdowns and notebooks for adequate documentation.
System walkdown item lists QTP 010-S12 and 513 have been completed for all systems requiring walkdowns.
During the last two quarters, all quarterly walkdowns were completed on time. QTP 010-S14, Quarterly System Waivers, are presently being completed and will be done by January 15, 1993.
ZNLD/2447-3
AUACllHENLB RESPONSE TO NOTICE OF VIOLATION I
NRC INSPECTION REPORT 50-254/92025; 50-265/92025 l
CORR LC H VLSI EPS JI!ALHI LLDL J AKE N_10lV01 DlVRJllEILVIOLAUONS ; (Exampie A)
To insure that the expectations of Tech Staff management are being met, a Tech Staff overview program has been implemented.
This overview includes use of procedures and follow through on discrepancies.
The system engineers are observed at least once by their group leader.
The Tech Staff Supervisor and the Assistant Tech Staff Supervisor assigned to supervise the system engineer groups, also perform overviews on a less frequent basis.
The overview program has been in place for only the last quarter of 1992, and its effectiveness will be reviewed and improvements made as necessary to continue improving Tech Staff Performance.
DAT E _ H!!EN JULLCOMPLI ANCL HI LLDE ACHI EVED:
(Example A)
Full compliance will be achieved on January 15, 1993, when all system item walkdown lists will be completed and reviewed.
REASON 10R_VIOLAHONI (Example B)
CECO acknowledges that the monthly reviews for several temporary alterations, installed between November 16, 1988, and August 21, 1991, were not performed within four months of the installation dates.
However, QTP 300-22 does not require that monthly reviews be completed within four months of the installation date as stated in the violation.
A few cases did exist where the reviews were substantially overdue; however, the majority of the reviews were completed in an acceptable time frame.
The procedure lacked specific guidance on when the 3 month review was required to be completed.
The cause for violation is a lack of procedure clarity and management oversight.
CORRECTIVE _SIEPS_TAKEN AND_.RESULIS ACilIEVED:
(Example B)
QTP 300-22, " System Temporary Alteration Review", has been revised to include an additional statement in section F;2, that clarlfles the method the evaluator will use to determine when the 3 month review is required.
The procedure provides a one month buffer time to perform the evaluation and have it reviewed.
Since August 21, 1992, timely evaluations have oeen performed.
This violation has heightened the awareness of the cognizant individual in charge of temporary alteration reviews.
CORRECUVLSTEPS_IllAT. HILLBLTAKENJ0_ AVOIDJURTilER SIOLATIONS:
(Example B)
No further corrective steos are required.
ZNLD/2447-4
AIIACHMENLA RESPONSE TO NOTICE Of VIOLATION NRC INSPECTION REPORT 50-254/92025; 50-265/92025 DM E_NHEM_EULLCOMELI ANCLHILLDE_AC111EXEDI (Exampie B)
Full compliance was achieved on January 8, 1993, when a procedure change to QTP 300-22 was implemented.
REA50!LEOR_VIDLATION; (Example C)
CECO acknowledges that the monthly reviews for 26 temporary alterations, all installed between November 16, 1988, and April 19, 1991, did not address one or more of the concerns outlined in the QTP 300-22 procedure.
CORRECUVLSIEES_IAKEttAND_RESULLSlC!LIEVEQ1 (Exampie C)
The surveillance procedure QTP 300-535 was promptly corrected with specific instructions to address all concerns required by the procedures.
Since October 10, 1992, there have been timely evaluations, addressing concerns outlined in the system temporary alteration implementing procedure QTP 300-22.
CORRECTED _SIEESJHAI_NILLBE TAKEM_IO_ AVOID _EURIHER_VIOLAll0NSI (Example C)
No further corrective steps are required.
DATENH EN_EU LLCOMELIANCLMILL_DLAC!lI EYLDJ (Exampie C)
Full Compliance was achieved on October 10, 1992, when procedure QTP 300-S35 was revised and implemented.
meu ZNLD/2447-5
AII6CliMENT_D RESPONSE 10 UNRESOLVED ITEM NRC INSPECTION REPORT 50-254/92025; 50-265/92025 UNRESOLVED.IIEM: 254(265)/92025-02 The discovery of the design deficiency was the result of an ongoing licensee program to recapture portions of the design basis, and overall is considered positive.
However, design deficiencies which have a potential impact on plant operations and the ability to mitigate design basis accidents require prompt management attention and timely corrective action.
The failure to promptly identify and correct the SBGT design issues is considered an unresolved item (254/265)/92025-02 (DPR), pending licensee response as to how emergent design issues are identified and resolved, with appropriate compensatory actions taken.
DISCUSSION; The issue in question was identified during the Master Equipment List (MEL)
Update project by Sargent and Lundy working under the direction of the BWR Systems Design group.
An Operability Assessment (ENC-QE-40.1) performed by BWR Systems Design originally concluded that the SBGT system was operable and in accordance with its design basis.
After being questioned by Station personnel and the NRC Resident, Revision 1 of the assessment concluded that the current design basis was not met and the condition was reportable.
Revision 2 of the assessment required additional compensatory measures until a modification can be performed.
RESPONSE; The need to make changes in the Nuclear Engineering Department (NED) to make the organization nore responsive to Station needs was identified in mid-1992.
Currently, NED is undergoing a significant reorganization as part of a Nuclear Operating Division and company wide restructuring.
The engineering changes have the expressed purpose "to:
I Bring all site resources devoted to design engineering and construction under a single manager on-site.
Focuses accountability for station configuration control under a single manager that reports directly to the site Vice President (VP).
Establishes accountability for long-term design matters of the station within the site organization.
Provides that to the extent practical, all plant specific design engineering for the station is performed on-site."
The Station Support Engineering Supervisor and the Modification Design Supervisor will have the primary engineering " responsibility and accountability for design control and site specific design expertise." They will report to the site Engineering and Construction Manager and the site-VP.
The groups under these supervisors are being formed from Downers Grove engineering, site engineering, Station Technical Staff, and other groups.
It is anticipated that the new groups will have individuals with a variety of backgrounds and experiences, including operating licenses, design engineering, and systems engineering.
ZNLD/2447-6
ATIACHMENI_B RESPONSE TO UNRESOLVED ITEM NRC INSPECTION REPORT 50-254/92025; 50-265/92025 In summary, under the new organization the design responsibility has been decentralized and the responsibility for Operability Assessments will be on-site.
The individuals performing these assessments will have a wide background, including more plant experience.
Communication should improve, because of the increased face-to-face contact and closer proximity to engineering's customer, the Station. Accountability will improve with station and station support personnel reporting to the site-VP.
He are confident the new CECO organization will allow CECO to move forward and be more responsive when emergent design issues are identified.
i l
ZNLD/2447-7