ML20136E827
| ML20136E827 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/06/1997 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ESK-97-054, ESK-97-54, NUDOCS 9703130335 | |
| Download: ML20136E827 (9) | |
Text
Commonweahh Edium Company Quad Cities Generating Station 22710 2(6th Avenue North Cordova, 11.61212 9710 I
Tei yv> m 221:
i ESK-97-054 March 6,1997
'U.S. Nuclear Regulatory Commission Washington, D. C. 20555
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l Attention:
Document Control Desk
Subject:
Quad Cities Station Units 1 and 2; NRC Docket Numbers 50-254 and 50-265:
NRC Inspection Report Numbers 50-254/96-017 and 50-265/96-017
Reference:
J. Grobe to E. S. Kraft, Jr. Letter dated February 4,1997 Concerning Three Notices of Violation.
Enclosed is Commonwealth Edison's (Comed's) response to the three Notices of Violation transmitted with the referenced letter. The first violation concerned a failure of design control which resulted in incorrect bolts being used in the RHRSW pump. The second violation concerned the failure to notify the NRC of the above condition in accordance with 10 CFR 50.73. The third violation concem:d a procedure that failed to require a charcoal adsorber test afler 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation.
This letter contains the following commitments:
- 1. An LER will be submitted by March 27,1997 to document the use ofimproper pump casing bolts.
- 2. A Training Request (TR) and an accounting of the charcoal adsober event will be sent to the Curriculum Review Committee (CRC). The CRC will evaluate the event and root cause, determine if additional training is needed, and provide training as required. This will be completed by November 21,1997.
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- 3. Conduct awareness training at Engineering meeting (s) to ensure that the System Engineers understand that surveillances must satisfy the literal interpretation of the Technical Specifications. This will be completed by March 31,1997 g,
9703130335 970306 PDR ADOCK 05000254 G
@.N A Unicom Company
2 March 6,1997
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I If there are any questions concerning this response, please contact Mr. Charles Peterson, Regulatory Adairs Manager, at (309) 654-2241 extension 3609.
Respectfully,.
/f&t E. S. Kraft, Jr.
Site Vice President i
Quad Cities Station Attachment (A), Quad Cities' Response to An Apparent Violation ec: A. B. Beach, Regional Administrator - RIII C. G. Miller, Senior Resident Inspector - Quad Cities R. M. Pulsifer, Project Manager - NRR W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company M. E. Wagner, Licensing, Comed -
DCD License (both electronic and hard copy) l i
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1 2
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ATTACIIMENT A ESK-97-054 (Page 1 of 7)
NOTICE OF VIOL.ATION (254-100-96-01702)
During an NRC inspection conducted on October 27 through December 6,1996, three j
violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG 1600, the violation is listed below:
2.
Appendix B of 10 CFR Part 50, Criterion III, " Design Control," requires in part that measures shall be established for the selection and review for suitability of application of parts that are essential to the safety-related functions of the structures, systems, and components.
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Contrary to the above, incorrect bolts were used in the IC and 2C safety-related residual heat removal service water (RHRSW) low pressure pumps. The incorrect Grade B8 replacement bolts had lower yield strength than was required for use in the pumps during the period October 8 through October 27,1996, for the IC RHRSW pump and July 12 through October 28,1996, for the 2C RHRSW pump and caused the pumps to be inoperable.
i This is a Severity Level IV violation (Supplement I).
REASON FOR VIOLATION:
This' event was caused by a failure of the Materials Engineering Group to follow the established procedure and checklist when performing the pans' evaluation. This failure prevented them from recognizing the less conservative design change they had approved.
Since the improper procedure and checklist was used to perform this parts' evaluation, the Material Engineering Group personnel responsible for the parts' evaluation did not recognize the need to notify Quad Cities Station that lower strength bolts had been approved, and that a corresponding lower torque value was required.
ACTIONS TAKEN:
The substandard bolts approved by the Materials Engineering Group's evaluation were subsequently replaced with bolts that met the original design specification for the RHR SW LP Pumps. These bolts were evaluated and approved on Quad Cities Station parts' evaluation Q-1992-0013-10 prior to being installed in the affected pumps.
ATTACIIMENT A ESK-97-054 (Page 2 0f 7)
ACTIONS TO PREVENT FURTIIER OCCURRENCE:
The entire staff of MEG engineers has been provided official clarification on the importance of evaluating non-like-for-like material changes on the prescribed ME-P7, Alternate Replacement Evaluation checklist, and has also been provided clarification on the importance of reviewing torquing allowables when evaluating alternate fastener materials.
The clarification to the MEG engineering staff on the importance of utilizing the prescribed checklist for all alternate replacements was completed on February 21,1997.
The clarification on the importance of reviewing torquing allowables when evaluating alternate fastener materials was also completed on February 21,1997.
DATE WIIEN FULL COMPLIANCE WILL BE MET:
Full compliance was met with the completion of the clarification to the MEG stafron February 21,1997.
ATTACHMENT A ESK-97-054 (Page 3 of 7)
NOTICE OF VIOLATION (254-100-96-01704)
During an NRC inspection conducted on October 27 through December 6,1996, three violations ofNRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG 1600, the violation is listed below:
4.
10 CFR 50.73 Section (a)(2)(1)(B) " License Event Report System," requires the licensee to report any condition prohibited by the plant's Technical Snecifications within 30 days after the discovery of the event.
j Contrary to the above, on October 25,1996, the licensee discovered that Unit 2 had been operated in a condition prohibited by plant Technical Specifications 3.5.B.2 and 3.5.B.5. Specifically, between July 12 and October 25,1996, Unit 2 was operated for a period in excess of 30 days with the 2C RHRSW pump inoperable (see Item 1 above), a condition prohibited by Technical Specifications.
The licensee failed to report by November 24,1996, the discovery that Unit 2 had operated beyond the Technical Specification allowed 30 days.
This is a Severity Level IV violation (Supplement I).
REASON FOR VIOLATION:
This violation resulted from a failure to follow the normal process for dispositioning Problem Identification Forms (PIFs) by the event screening committee (ESC). PIFs are normally reviewed by the ESC on the next working day following their origination.. The ESC reviews the PIF and establishes the significance level, reviews the operability and reportability determinations made by the Shift Engineer and determines if any additional reporting requirements (i.e.10 CFR Part 21, LER, INPO Nuclear Network, etc.) are necessary. When the PIFs which documented the problems with the Residual Heat Removal Service Water (RHRSW) pump bolting material were ieviewed by the ESC, additional information was requested from Engineering in order for the committee to decide if they agreed with the operability determination made by the Shift Engineer. The ESC did not complete the required screenings of the PIFs at this time, but deferred the screening until the additional information was obtained. Subsequently, tracking of these PIFs were inadequate, and the thirty day allowable time for reporting the event expired before the additional information was obtained.
1 ATTACHMENT A
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ESK-97-054 (Page 4 of 7) j ACTIONS TAKEN:
This event was discussed at the ESC to reemphasize to all members the importance of timely processing of PIFs. In order to achieve improved tracking of open items, the ESC established a routine item on the agenda of each meeting to discuss PlFs which have either not been to the ESC or were placed on hold for additional infonnation.
ADDITIONAL ACTIONS:
1.
An LER will be submitted by March 27,1997 to document the use ofimproper pump casing bolts.
DATE WHEN FULL COMPLIANCE WILL BE MET:
Full compliance will be achieved on March 27,1997 following submittal of the LER.
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a ATTACHMENT A ESK-97-054 (Page s or7)
NOTICE OF VIOLATION (254-100-96-01706)
During an NRC inspection conducted on October 27 through December 6,1996, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG 1600, the violation is listed below:
6.
Appendix B of 10 CFR Part 50, Criterion XI, " Test Control," requires, in part, "A test program shall be established... and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents."
Technical Specification (TS) 4.8.D.4 requires aner 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, that a laboratory analysis of a representative carbon sample be obtained.
Quad Cities Technical Staff procedure (QCTS) 440-03, " Control Room Emergency Filtration System (CREFS) Removal of Charcoal Adsorber Test Canister," Revision 3, dated January 19,1996, was the procedure the licensee used to ensure TS requirement 4.8.D.4 was met.
Contrary to the above, procedure OCTS 0440-03, had not included the requirement to sample the charcoal adsorber aner 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation.
This is a Severity Level IV violation (Supplement I).
50-254/265-96017-06(DRP).
REASON FOR VIOLATION:
i The reason for the violation was a cognitive personnel error, per the following explanation.
Per the Upgraded Technical Specification 4.8.D.4, a laboratory analysis of a representative carbon sample must be performed after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation.
This requirement was not included in the previous Technical Specifications (TS). Before the Upgraded Technical Specifications were implemented, a review was done by the Operations Department and the System Engineering Department to verify that each surveillance requirement was satisfied. Specifically, QCTS 0440-03 was revised to satisfy the upgraded Technical Specifications.
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ATTACHMENT A ESK-97-054 (Page 6 of 7)
The surveillance requirement of TS 4.8.D.4 was considered to be satisfied by the new revision of procedure QCTS 0440-03. A recent review of QCTS 0440-03 revealed that it does provide for removal of a charcoal adsorber test canister for laboratory analysis.
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However, QCTS 0440-03 is an eighteen month procedure, and does not provide a vehicle for tracking the hours of charcoal adsorber operation.
r The error that led to this violation is that the system engineer revised QCTS 0440-03 to satisfy the upgraded Technical Specifications, and took credit for satisfying the j
surveillance requirement of technical specification 4.8.D.4, without ensuring that the charcoal would be tested in the event that the system is run for greater than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> in less than 18 months. The system engineer considered the requirement to sample the charcoal adsorber after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation to be bounded by the 18 month frequency for procedure QCTS 0440-03.
ACTIONS TAKEN:
System Engineering performed a review of the computer point M267, "AFU outlet flow,"
Operations Surveillance QCOS 5750-02, " Control Room Emergency Filtration System
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Monthly Test," and the unit NSO logs from the time of the last charcoal sample, April 25, 1995 to December 4,1996. The total estimated hours for run time on the charcoal was 379 hours0.00439 days <br />0.105 hours <br />6.266534e-4 weeks <br />1.442095e-4 months <br /> and 2 minutes. This review used the computer data from June 2,1995 to
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December 4,1996, and included the computer down time of 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> and 12 minutes as a conservative measure. Since there is no computer data available for the period of April 25,1995 to June 2,1995, the monthly surveillance's were used to collect the run times for
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that time frame.
The estimate of 379 hours0.00439 days <br />0.105 hours <br />6.266534e-4 weeks <br />1.442095e-4 months <br /> and 2 minutes of run time, as derived above, is significantly lower than the 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> maximum specified by the technical specifications. Therefore, the Control Room Emergency Filtration System (CREFS) was not declared inoperable.
QCTS 0440-03, " Control Room Emergency Filtration System Removal of Charcoal Adsorber Test Canister," was revised on March 5,1997 to include the requirement to perform a test canister laboratory analysis after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation.
QCTS 0810-08, "In-plant Inspection of HVAC Systems," was revised on March 3,1997 to include a monthly recording of the hours of charcoal adsorber operation from the last sample, with directions to perform a sample if the 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> limit is approached.
ATTACHMENT A ESK-97-054 (Page 7 of 7)
Procedures QCOS 5750-02, " Control Room Emergency Fuisetie.n System Monthly Test,"
QCOS 5750-11, Control Room Emergency Filtration System 18 month test," and QCOP 5750-09, " Control Room Ventilation," were revised on February 18,1997 to instruct operators to log starts and stops of the air filtration unit in the unit 2 NSO logs.
System Engineering continued to monitor charcoal adsorber run times until QCOS 0810-08, "In-Plant Inspection of HVAC Systems," was revised to monitor the run times. The 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> limit was not approached.
An investigation was performed for the control room HVAC to ensure that any other technical specification issues were identified and corrected.
ACTIONS TO PREVENT FURTilER OCCURRENCE:
The following corrective actions are scheduled to be implemented, as a result of the investigation of this event, as documented on Problem Identification Form (PIF) 96-3413:
- 1. Conduct awareness training at Engineering meeting (s) to ensure that the System Engineers understand that surveillances must satisfy the literal interpretation of the Technical Specifications. This will be completed by March 31,1997.
(NTS # 254-201-96-34303)
- 2. Submit a Training Request (TR) and an accounting of this event to the Curriculum Review Committee (CRC). The CRC will evaluate the event and root cause, determine if additional training is needed, and provide training as required. This will be completed by November 21,1997. (NTS # 254-201-96-34304)
DATE WIlEN FULL COMPLIANCE WILL BE MET:
Full compliance for this event was met on March 5,1997.
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