ML20128C418
| ML20128C418 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/22/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0052K, 52K, NUDOCS 8505280290 | |
| Download: ML20128C418 (6) | |
Text
-
. ' y,. : e.
r'N Commonwealth Edison
) One First National Plaza, Chicago, Ilhnois G ] Address Reply to: Post Office Box 767 j Chicago. Illinois 60690 May 22, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
-Quad Cities Station Units 1 & 2 Response to Inspection Report Nos.
50-254/85-02 & 50-265/85-02 NRC Docket Nos. 50-254 & 50-265 Reference (a):
J. G. Keppler letter to Cordell Reed dated April 2, 1985.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
R. A. Hasse & R. N. Sutphin during the period January 21, through February 7, 1985 of activities at Quad Cities Station. Reference (a) indicated that certain activities appeared to be in noncompliance with WC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours,
($
k D. L. Fa Director of Nuclear Licensing 1m Attachment cc:.NRC Resident Inspector - Quad Cities MAY 2 31985 8505280290 850522 I
0052K gDR ADOCK 050 4
i \\
M
r.
)
ATTACHENT COMMONWEALTH EDISON COM'ANY RESPONSE TO NOTICE-0F VIOLATION A. ' The Standby Gas Treatment System (SBGTS) was modified by the installa-tion of-jumpers intended to bypass the heater high temperature cutoff switches, without the benefit of either an on-site review (as required by Technical Specification, Section 6.1.G.2.a.4) or a post-installation test to verify the installation's adequacy.- The jumpers were installed across the wrong terminals; when the SBGTS was called upon to operate,
- due to the loss of the Reactor Protective System 1 D MG set, the heaters in both trains tripped.
DISCUSSION On July 19, 1983, the Environmental Qualification of Electrical Equipment (EQEE) project identified that the heater high temperature cut out switches on the Standby Gas Treatment System (S8GTS) were not required. On August 18, 1983 the Station Nuclear Engineering Department (SED) presented a formal recommendation to the Station to remove the temperature switches. The Station requested SED's assistance in engineering the modification and SED issued the modification approval on March 13, 1984. On August 1, 1984, due to spurious SBGTS heater trips cau~ed by the temperature switches, jumpers were installed to s
delete the switches from the circuit. The jumpers were installed in accordance with procedure QAP 300-12, " Electrical Jumpers and Relay Blocks", and the existing corporate directive for jumper placement. An error was made on the placement of the jumpers due to the use of an q
incorrect electrical wiring drawing. When the SBGTS was called upon to j
operate on August 2, 1984 both trains were declared inoperable due to i
the failure of the electrical-heaters. Licensee Event Report 84-12 was initiated.
I CORRECTIVE ACTION'TAKEN Af0 RESULTS ACHIEVED The immediate corrective action taken was to correct the placement of L-the jumpers and to replace the damaged control transformers in each train's heater logic circuit. Both S8GTS Trains were operable within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the initial failure. Subsequently, the jumpers were removed I
when the modification to remove the temperature switches was completed I
on each train.
1
.. CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTER NONCOM)LIAPCE Technical Staff Engineers have been instructed to more rigorously inspect actual plant configurations when working on modifications.
In addition, Corporate Directive NSDD-A09 " Conduct of Operations", section 5.3.10 " Bypass of Safety Functions and Jumper Control" is being revised to consider placement of a jumper as a potential modification. Jumpers which impact safety functions will require an on-site review and approval prior to the placement of the jumper except during backshift circumstances. Station procedures shall be modified to comply with the Directive.
DATE WHEN FULL-COM'LIANCE WILL BE ACHIEVED Full-compliance is expected to be achieved when station procedure revisions are completed by July 30, 1985.
B.
In 1980 a modification was made to the control circuit of the Unit 1 Low Pressure Coolant Injection (LPCI) valves to prevent valve hammer during a continuous close signal. An error was made in the preparation of thG -
wiring dlagrams at the station and the resulting installation was in error. The error was not detected by either the subsequent review and approval of these diagrams or the tests performed after installation.
DISCUSSION In 1973 a modification was initiated by the Station to prevent valve hammer during a continuous close signal on the Unit 1 Low Pressure Coolant Injection (LPCI) valves. In 1976 the Station received the approval'from SNED to proceed with the modification. Several months later, in 1976, the Station returned the modification' to SPED for preparation of the necessary wiring diagrams. In July 1979, the Station provided SED with wiring diagrams and requested SED to approve and return them to the Station. In August 1979, SED approved the wiring diagrams. On November 26, 1980, the Station completed the modification, and on November 27, 1980, the modification test was complete. The error in the wiring of the modification was not discovered during the modification test because the motors on the injection valves had motor brakes on them to prevent valve hammering at the time of modification.
Lm
-r g
- i f
b
~,
g
[
I0n' July 29,1984, the_ thit One LPCI valve motors.were replaced as part iof the EQEE project. These new valve motors did not include motor r
brakes. ?The wiring error in the 1980 modification allowed the valves to hammer and become damaged.
CORRECTIVE ACTION TAKEN APO RESLLTS ACHIEVED
~-The=immediate corrective action _taken-was to repair the valves and to.
correct the wiring' errors. All valve circuits modified under the 1980 modification were examined prior to the startup of the unit. Also, all valve motors which were replaced as part of the EQEE project were
! examined prior to the startup of the unit. The necessary corrections swere made.and the valves examined prior to unit startup.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTER NONCOWLIANCE The Station has formalized print design review for Safety-Related modifications, engineered on-site. The review requires an independent
+
design review by SNED. Additionally, the Station has implemented a new
. procedure providing guidelines for preparing Modification Tests and instructed appropriate personnel in its use.
SED has also formalized its review.of station generated design prints.
'SNED now requires all wiring diagrams furnished by the Station to be
're-drafted and receive an independent design review by a SNED approved design' organization. This change will be formally incorporated in SNED-Procedure Q.6.
'DATE WiEN FlLL COWLIANCE WILL-BE ACHIEVED Full compliance has been achieved for by the Station. Compliance by SED will be formally achieved by the implemetation of Q.6 by June 15,
~
1985.-
' C.:-' The Unit 1 Steam Jet Air Ejector (SJAE) suction valves were replaced
~
- ewith butterfly valves. The design review and installation package did
- not' identify that the valves could be installed in different orientations. Because of their subsequent incorrect installation, indication in the control ~ room was opposite of actual, valve position.
.The misorientations were detected while attempting to draw a vacuum on X
the condenser during.startup.
E f
~
A
=. -._
1 DISCUSSION In July,~ 1984, the Steam Jet Air Ejector (SJAE). Suction Valves were replaced with a more reliable. valve. -On August 8, 1984, the Station completed -the modification' test of the~ new S]AE suction valve. On August'16, 1984, when starting up the unit and trying to draw main condenser vacuum, it was discovered that the butterfly valve disc had been installed 90 degrees out of proper orientation. Actual valve position was exactly. opposite of the indicated position in the Control Room.and locally at the valve. In the modification package, neither the
-Station nor SNED specified a procedure or instructions regarding valve assembly. The modification package relied on the craft capability to correctly assemble the valves.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The immediate corrective action taken was to repair the SJAE suction valves by rotating the discs 90 degrees and properly reinstalling the operator. This allowed vacuum to be established on the main condenser and normal unit startup.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTFER NONCOWLIANCE The Station has implemented a new procedure " Disassembly, Repair, and
. Reassembly of Safety-Related Butterfly, Ball, and check valves with Pneumatic or Hydraulic Actuators". This procedure includes guidance on proper assembly of valve discs to shafts.to preclude orientation errors. In addition, discussions have been held with the Technical Staff Engineers emphasizing the need for thorcugh modification tests.
The implementation of the new " Guidelines for Development of Tests fcr Modifications" procedure QTP500-6 will also aid in the proper preparacion of future modification tests. Corporate Directive NSDD-A09 will be revised to address post maintenance and post modification test requirements.
~.
DATE~ WiEN FlLL COWLIANCE WILL BE ACHIEVED
^
The Station is currently in full compliance. NSDD-A09 will be revised June 1, 1985.
D.
A 2" tee and flange were added to the Unit 1 bottom head drain line of the' Reactor Water Clean Up (RWCU) system. This modification was approved, installed, and declared operational without the benefit of a stress analyses as required by~FSAR Section 12.1.3.
_q t iJ DISCUSSION On March 23, 1984 the Station received advanced approval on installation of a 2". tee and flange to.the Unit One bottom head drain line (which is attached to the reactor water cleanup system). The tee was to-facilitate chemical decontamination of the reactor vessel recirculation piping. On May 9,1984 the installation' of the modification was complete. And on July 11, 1984 the modification test was completed in conjunction with the vessel hydro. It was during the hydro that a significant vibration was identified on the tee and flange installation.
CORRECTIVE ACTION TAKEN AND RESULTS-ACHIEVED Subsequent analysis performed by SED has indicated that the initial design review performed for this modification was adequate in that installation of the tee and flange did not affect the safe operability of the piping.
CORRECTIVE ACTION TO BE TAKEN TO AVOIO FURTHER NONCO W LIANCE By letter dated March 14, 1985 all Project Engineers were instructed to require a full-documented design evaluation to be performed prior to placing a system in service. This requirement will be met for'all applicable modifications, including applicable advanced approval modifications. This will be formally implemented in SED Procedure Q.6.
DATE WE N FULL COWLIANCE WILL BE ACHIEVED
-Both the Station and SNED are in full compliance.
L0052K
~